background document for the testing of...

Background Document for The Testing of Communication Vehicles in the Environmental Footprint Pilot Phase 2013-2016

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BACKGROUND DOCUMENT

FOR THE TESTING OF COMMUNICATION VEHICLES

IN THE ENVIRONMENTAL FOOTPRINT PILOT PHASE

2013-2016


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Contents

1 Using this document ....................................................................................................................... 4

1.1 Purpose ................................................................................................................................... 4

1.2 Glossary ................................................................................................................................... 4

1.3 List of acronyms ...................................................................................................................... 5

1.4 Terminology: shall, should and may ....................................................................................... 6

2 General principles ........................................................................................................................... 6

3 The communication stage of the EF pilot phase ............................................................................. 8

3.1 The aim of EF communication ................................................................................................ 9

3.1.1 PEF Profiles ...................................................................................................................... 9

3.1.2 OEF Profiles ................................................................................................................... 10

3.2 Gathering feedback ............................................................................................................... 11

4 Choosing communication vehicles ................................................................................................ 12

4.1 Information to be provided by TSs ....................................................................................... 13

5 Implementation of communication vehicles ................................................................................ 14

5.1 Product EF Profile information ............................................................................................. 14

5.2 Organisation EF Profile information ..................................................................................... 15

5.3 Using behavioural insights for B2C communication ............................................................. 15

6 Bibliography .................................................................................................................................. 19

Annex I – Examples of communication vehicles ................................................................................... 20

1. PEFCRs ....................................................................................................................................... 20

A. At the Point of Sale (POS)...................................................................................................... 20

Co-existence with existing labels or certifications ........................................................................ 24


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B. Close to the POS .................................................................................................................... 25

C. Beyond the POS .................................................................................................................... 26

2. OEFSRs....................................................................................................................................... 28

A. Report and related ................................................................................................................ 28

B. B2C vehicles .......................................................................................................................... 30

Annex II – Decision matrix for the choice of communication vehicles ................................................. 32

PEFCR based communication ............................................................................................................ 32

OEFSR based communication ........................................................................................................... 34


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1 Using this document

1.1 Purpose

This paper is drafted by the European Commission services based on previous analysis and

experience on this subject (see Bibliography). It will be updated throughout the duration of the pilot

in order to reflect insights from the pilot process and optimise implementation.

The purpose of the document is to provide guidance for use in the Environmental Footprint Pilot

Phase of 2013-2016. It aims to provide guidance for the Technical Secretariats in the definition of the

communication vehicles to test, their implementation and the evaluation of their effectiveness. The

guidance covers both Product Environmental Footprint (PEF) and Organisation Environmental

Footprint (OEF) related communication, and both B2B and B2C target audiences.

1.2 Glossary

The terminology is defined for the use in this document and is not meant to substitute any

definitions of official EU documents and legislation. The definitions complement those provided in

the Guidances for the implementation of the EU Product and Organisation Environmental Footprint

during the Environmental Footprint pilot phase1 (henceforward: Guidances).

Business to Business (B2B) – Describes transactions between businesses, such as between a

manufacturer and a wholesaler, or between a wholesaler and a retailer. In an Environmental

Footprint communication context, it refers to Environmental Footprint Profile information that is

provided on the products offered or the environmental performance of an organisation to another

business.

Business to Consumers (B2C) – Describes transactions between business and consumers, such as

between retailers and consumers. According to ISO 14025:2006, a consumer is defined as “an

individual member of the general public purchasing or using goods, property or services for private

purposes”. In an Environmental Footprint communication context, it refers to Environmental

Footprint Profile information that is provided directly to the consumer related to a product or an

organisation.

Communication vehicle – Any means conveying life cycle environmental performance information

to consumers (B2C) or business partners (B2B). For example, communication vehicles include

performance labels, performance improvement labels, barcodes, on-shelf information, instruction

manuals, product declarations, consumer receipts, printed information material, websites, apps,

campaigns, 3rd party schemes, reports, sustainability rankings, etc. A list of examples and

explanations are given in Annex I.

Environmental Footprint (EF) Profile – the quantified results of a Product Environmental Footprint

(PEF) or an Organisation Environmental Footprint (OEF) study. It includes the quantification of the

1 For the latest version, see http://ec.europa.eu/environment/eussd/smgp/pdf/Guidance_products.pdf and

http://ec.europa.eu/environment/eussd/smgp/pdf/Guidance_organisations.pdf

http://ec.europa.eu/environment/eussd/smgp/pdf/Guidance_products.pdf

http://ec.europa.eu/environment/eussd/smgp/pdf/Guidance_organisations.pdf


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impacts for the most relevant impact categories and the additional environmental information

considered necessary to be reported.

Integrated Report (IR) – An integrated report is a concise communication about how an

organization’s strategy, governance, performance and prospects, in the context of its external

environment, lead to the creation of value in the short, medium and long term. It communicates the

full range of factors that materially affect the ability of an organization to create value over time

(these may be economic, environmental or social factors), integrating them in a single report

(definition based on International Integrated Reporting Council).

Public Relations (PR) – It is the practice of managing the communication between an organization

and its ‘publics’. PR gains an organization exposure to their audience(s) using topics of public interest

and news items that provide third-party endorsement and do not involve direct payment. The aim of

public relations by a company often is to persuade the public, investors, partners, employees, and

other stakeholders to maintain a certain point of view about it, its leadership, products, or of

political decisions (definition based on Wikipedia).

Technical Secretariat (TS) – The TS is leading the development of a PEFCR or OEFSR, is proposing the

draft rules, organises meetings and stakeholder consultations. For a list of activities of the Technical

Secretariat, please refer to the Guidances.

1.3 List of acronyms

Acronym Expansion

B2B Business to Business

B2C Business to Consumer

EF Environmental Footprint

ELCD European Life Cycle Database

EMAS Eco-Management and Audit Scheme

EoL End of Life

EPD Environmental Product Declaration

FRT Sustainable Consumption and Production Food Round Table

GHG Greenhouse Gas

GRI Global Reporting Initiative

LCA Life Cycle Assessment

MS Member State

NGO Non-Governmental Organisation

OEF Organisation Environmental Footprint

OEFSR Organisation Environmental Footprint Sectorial Rule

PEF Product Environmental Footprint

PEFCR Product Environmental Footprint Category Rule

POS Point of Sale

SC Steering Committee

SME Small and Medium Enterprise

TAB Technical Advisory Board


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1.4 Terminology: shall, should and may

The term “shall” is used to indicate what is required in order for EF communication to be in

conformance with this document and the Guidances.

The term “should” is used to indicate a recommendation rather than a requirement. Any deviation

from a “should” requirement has to be justified when developing the PEFCR/ OEFSR and made

transparent.

The term “may” is used to indicate an option that is permissible. Whenever options are available,

the PEFCR/OEFSR shall include adequate argumentation to justify the chosen option.

2 General principles The principles defined in the Commission Communication "Building the Single Market for Green

Products - Facilitating better information on the environmental performance of products and

organisations"2 shall be valid for any form of communication implemented during the Environmental

Footprint (EF) pilot phase.

Explanatory notes added for the purpose of the Environmental Footprint Pilot are provided in italics.

These are:

(1) Transparency. Economic operators should release information not only on the

environmental performance of the products and organizations concerned, but also on the

way the information has been generated, namely on the assessment procedure, method,

data sources, criteria, etc. During the development of Product Environmental Footprint

Category Rules (PEFCRs) and Organisation Environmental Footprint Sector Rules (OEFSRs),

this includes the consultation of stakeholders regarding the most effective ways of

communicating EF information. This also means that this type of information shall be

available on complementary vehicles, e.g. if space doesn't permit providing additional

information regarding the EF Profiles (e.g. label paired with a website where background

information is available).

(2) Availability and accessibility. Economic operators should display the information

concerning environmental performance of the product in relation to the most relevant

environmental impacts in a simple and immediately understandable format. The essential

information should be complemented by making available for consultation detailed

information through additional channels, such as websites, smartphone applications, etc.

In order to be understandable, the number of indicators communicated to consumers shall

be limited to 3. The use of a complementary aggregated indicator (weighted score) should

be considered3.Detailed information made available includes technical information on how

2 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52013DC0196:EN:NOT

3 See Bio Intelligence Service for the European Commission (2012): Study on different options for

communicating environmental information for products

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52013DC0196:EN:NOT

http://ec.europa.eu/environment/eussd/pdf/footprint/ProductsCommunication_Final%20Report.pdf



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the PEF profile was calculated, including assumptions, limitations and uncertainty of

information.

(3) Reliability. The information communicated should be scientifically accurate and verifiable

to ensure users' confidence in the green claim4. The EF pilot phase was devised in a way to

fulfil the reliability criterion. Factors contributing to reliability are the use of proven LCA

principles, the use of a multi-stakeholder process for defining the rule and the use of review

and verification both regarding the process and the EF results.

(4) Completeness. Economic operators should provide information on all environmental

impact categories that are relevant for the product and the organisation concerned in a

cost-effective way. Data communicated with any communication vehicle shall be based on

the most recent version of the PEFCR or OEFSR available at the time when the

communication activity is implemented; a reference to the version number or date shall be

included. It shall include data on environmental impact categories and life cycle stages

identified as relevant and obligatory by the draft PEFCR or OEFSR. It is not possible to

communicate on a single issue (e.g. GHG reporting), unless the PEFCR or OEFSR justifiably

concludes that the overwhelming majority of impacts are related to this single issue.

(5) Comparability. Economic operators should make consistent methodological choices in

order to guarantee the comparability of environmental performance information related to

a specific product category or to sector over time. Whenever possible, they should use

methods that enable the comparison of environmental performance between products

belonging to the same product category and between organisations operating in the same

sector. If the PEF Guide and the PEFCRs are used in a correct way, this principle would be

met by piloters without additional steps to be taken. Piloters are also invited to reflect on

whether it is necessary to help consumers identify which products belong to the same

category and if yes, how to signal that to them.

(6) Clarity. Economic operators should present the information in a way that is clear, precise

and fully understandable for the users. The content of the information should be clear as

well: its range and complexity should be adjusted to the target audience, to the

characteristics of the product and to the purpose of the communication. It is implied that

the information shall be non-misleading. This also means that best practice related to green

claims shall be respected, including the avoidance of vague or non-specific terms such as

4 The expressions "environmental claims" or "green claims" refer to the practice of suggesting or otherwise

creating the impression (in the context of a commercial communication, marketing or advertising) that a

product or a service, is environmentally friendly (i.e. it has a positive impact on the environment) or is less

damaging to the environment than competing goods or services. This may be due to, for example, its

composition, the way it has been manufactured or produced, the way it can be disposed of and the reduction

in energy or pollution which can be expected from its use. When such claims are not true or cannot be verified

this practice can be described as 'greenwashing'. p.37 UCPD Guidance Document.

http://ec.europa.eu/consumers/events/ecs_2013/docs/environmental-claims-report-ecs-2013_en.pdf


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""environmentally safe", "environmentally friendly", "earth friendly", "non-polluting",

"green", etc.5

The choice of communication vehicles shall be based on existing analysis and insights regarding

communication vehicles (see Bibliography).

Furthermore, communication vehicles shall contain a reference to the EU EF Pilot to clarify towards

the target audience the context of the information.

3 The communication stage of the EF pilot phase First steps in the development of communication vehicle options may start when the screening of

the representative product/ organisation is completed and when it is clear which are the most

relevant environmental impact categories and life cycle stages for the given product group or sector.

The decision on which communication vehicles to test is taken by the Technical Secretariats. PEFCRs

and OEFSRs shall include a specific section describing the 3-4 ways of communicating the results to

different target audiences (B2B and B2C as appropriate) and will be thus subject to the scrutiny of

stakeholders and the Steering Committee. The consultation on communication vehicles should be

part of the 2nd consultation, which is due for months 19-20 of the EF Pilots.

The test of the chosen and agreed communication vehicles shall start after the supporting studies

are carried out and the results are available. Communication shall be continuous from this moment

until the end of the pilot. In the timeline below, steps with a relevance for the communication phase

are marked with a red box:

5 European Commission Guidelines for Making and Assessing Environmental Claims (2000)

http://ec.europa.eu/consumers/cons_safe/news/green/guidelines_en.pdf

2009 Guidance on the implementation/application of directive 2005/29/EC on unfair commercial practices,

Chapter 2.5 Misleading environmental claims

(http://ec.europa.eu/consumers/rights/docs/Guidance_UCP_Directive_en.pdf)

Environmental Claims - Report from the Multi-Stakeholder Dialogue, 2013

http://ec.europa.eu/consumers/documents/consumer-summit-2013-mdec-report_en.pdf


http://ec.europa.eu/consumers/rights/docs/Guidance_UCP_Directive_en.pdf



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As stated in the Guidances for the implementation of the EU PEF and OEF during the EF pilot phase,

"the chosen communication vehicles shall be tested at least by the companies carrying out the

PEFCR supporting studies during the last phase of the pilot phase" (henceforward, Communication

Testers). Communication Testers shall also assist the European Commission in gathering feedback on

the vehicles.

The European Commission intends to procure a contract (Communication Contractors) for

supporting the implementation and feedback-gathering regarding the communication vehicles. This

support is expected to be available by January 2015.

3.1 The aim of EF communication

3.1.1 PEF Profiles

It stands clear that consumers make purchasing decisions first of all based on quality and price, and

only then based on other factors, including environmental ones6. Environmental performance

information was demonstrated to influence purchasing decisions as long as the features of the

product perceived as essential by consumer (e.g. noise levels for washing machines) were

unchanged. Under these conditions consumers manifested a willingness to pay more for products

6 Flash Eurobarometer 256: Europeans’ attitudes towards the issue of sustainable consumption and

production, 2009; Flash Eurobarometer 367: Attitudes of Europeans towards building the Single Market for

green products, 2013; Special Eurobarometer 298: Consumer protection in the internal market

1st physical consultation (scope+draft representative product/organisation), SC

12/2016

M0

M3

M5- 8

M9

M10

M11

M13

M15-18

M19-20

M22-26

The Technical Secretariat starts working

EF screening on the representative product / organisation

Technical check of EF screening

1st virtual consultation

2nd draft of the PEFCR/ OEFSR including communication vehicles

(at least) 3 PEFCR/ OEFSR supporting studies

2nd consultation (final draft rules), can start communication

Independent review of the final PEFCR/ OEFSR, SC approval

End of EF pilot and communication phase

Ongoing communication, gathering feedback on vehicles

Draft PEFCR/ OEFSR

M14 Approval of draft PEFCR

http://ec.europa.eu/public_opinion/flash/fl_256_en.pdf

http://ec.europa.eu/public_opinion/flash/fl_367_en.pdf

http://ec.europa.eu/consumers/archive/strategy/docs/eurobar_298_report_final_en.pdf


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featuring a better environmental or energy performance. It is also clear that there is a difference

between willingness to purchase products that are more respectful to the environment and real

consumer behaviour – many declare that they would buy "green" products, but less do (value-action

gap). Environmental Footprint information is understood to act within similar limits.

In the framework of the EF Pilots we are examining on the one hand how environmental information

is used on the market, thus whether it triggers purchases based on environmental considerations by

consumers and in B2B relations; on the other hand, whether the availability of information can lead

to increased awareness of environmental issues and more environmentally friendly use of products/

consumer behaviour. Additionally, we are examining whether information may trigger an

improvement of the overall environmental performance of products along the life cycle.

It is understood that the limitations regarding the length of the exercise have a negative impact on

the effectiveness of changing awareness or behaviour, and the evaluation of these points shall take

this element into account.

Accordingly, main aims are:

help consumers (B2C) and business partners (B2B) make more informed choices through the

provision of reliable, comparable and clear environmental information;

to contribute to increasing the attractiveness of products with a PEF Profile or a better life

cycle environmental performance based on PEF for consumers;

to contribute to greener consumption (increased attractiveness of products with better than

average life cycle performance and change of behaviour due to well-targeted information

regarding the optimal use of products);

to raise awareness on environmental issues particularly relevant to a product;

to improve the environmental performance of products

o improved product design through the targeting of key environmental issues related

to the product (internal use);

o enabling competition based on life cycle environmental performance.

An additional aim of the EF pilot phase is to gather information on the effectiveness of different

communication vehicles in order to identify essential features for the communication of PEF Profiles.

3.1.2 OEF Profiles

The main target audience of OEF Profiles are company stakeholders such as investors, public

administrations, NGOs (e.g. consumer or environmental organisations). Consumers may be less

interested in organisation-level information, however, Communication Testers may also look into

effective ways of engaging with consumers based on OEF Profiles.

The main aims of communicating OEF information are:


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help the relevant stakeholders (e.g. NGOs, investors, public administrations, consumers) in

their decision-making by providing reliable, reproducible, clear and (whenever feasible)

comparable information on environmental issues that are relevant for the given

organisation;

use information as a reputational instrument towards business partners, public

administrations, stakeholders and, eventually, consumers;

raise awareness about environmental issues related to a given sector;

trigger improvements in the life cycle environmental performance of organisations, and,

indirectly, across the supply chain and in the target audiences of information.

An additional aim of the EF pilot phase is to look into how the information provided caters for the

need of different target audiences and on the effectiveness of different communication vehicles in

order to identify essential features for communicating OEF Profiles.

3.2 Gathering feedback

Communication Testers are expected to co-operate with the European Commission and the

Communication Contractors in gathering feedback on the testing of communication vehicles from

the target audience. The feedback sought should include:

Information on how, where and for how long the communication vehicle was implemented.

This information should include whether it was used in combination with other

communication efforts, even if these are not part of the EF communication phase but are

considered relevant for the effectiveness of the communication vehicle tested; or whether

there was cooperation with other Communication Testers in the vehicle's design and

implementation. Information should also include data on the costs of implementing the

communication vehicle (the latter data will be published by the Commission only in an

aggregated form).

Is the communication vehicle understood by the target audience? What are the strengths

and weaknesses of the vehicle from this point of view? How can problems of understanding

be removed/ prevented?

How effective is the communication vehicle in attracting the attention of the target audience

to the environmental issues communicated?

How effective is the communication vehicle in making the product in question more

attractive to the target audience (e.g. better image of the product due to displaying

environmental performance or due to the level of environmental performance)? Is there

evidence of it influencing purchasing choices and/or behaviour change in how the product is

used or disposed of? What conditions were observed for enhancing greener choices among

consumers in purchasing and/or product use?


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How did the communication influence the reputation of the organisation? Is there evidence

of it influencing relationship with different stakeholders/ investor interest or decisions / the

situation of the organisation in sustainability rankings? (OEFSRs only)

How effective is the communication vehicle or the communication effort in general to

influence the way the company is using environmental data? Is there any internal change

that the process triggered/ triggers (e.g. design choices, supply chain management, striving

for better performance of the product or organisation)? Is there any change in the

environmental performance of the product or organisation?

Any other information that the Communication Tester offers to help the evaluation of

communication vehicles (e.g. influence of cultural factors).

Contributing to gathering this information means that Communication Testers help the

Communication Contractors to engage with the tests' target audiences and take complementary

efforts for gathering feedback.

4 Choosing communication vehicles Communication vehicles shall in all cases respect the general principles laid down in this document.

A combination of tools can also be proposed as a vehicle. There might be communication vehicles

that may be used only in combination with other vehicles in order to fulfil the general principles

defined in this document.

The communication vehicles shall be furthermore chosen based on the specificities of the product or

sector, the conclusions of the PEFCR or OEFSR, the potential effectiveness and efficiency (cost vs

effectiveness) of the tool, and previous experience or analysis regarding the communication

vehicles.

Core criteria to use when choosing communication vehicles shall include:

(a) What is the target audience? (B2B, B2C, stakeholders e.g. public administration, NGOs,

investors)

(b) Are benchmark and performance classes established in the PEFCR/ OEFSR?

(c) Is there an important or overwhelming amount of impacts coming from the use/EoL phase

for the product or product portfolio (i.e. is there a need to influence how the consumer uses

or discards the product)?

(d) Is the communication vehicle self-standing or should it rather be used in combination with

other vehicles?7

7 In this case, self-standing is intended as understandable / conveying sufficient information on its own, which

doesn’t exclude the need to provide further information on other media in order to satisfy criteria such as

transparency and completeness. Accordingly, used in combination means a situation where the information

provided through the vehicle is not understandable or would be misleading on its own.


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(e) Is the purchasing decision taken mostly on-spot or mostly after some reflection? (this

criterion applies only for products)

(f) What is the needed frequency of changing/ updating data (as specified in the PEFCR/

OEFSR)8?

(g) How costly is the use of the vehicle? Is it accessible to SMEs?

(h) Other determinants based on the specificities of the product or organisation.

(i) (Final check) Do the vehicles chosen fit with the general principles laid down in this

document (see Chapter 2)?

The Communication Testers may use additional criteria for choosing the communication vehicles to

test. The criteria shall be presented as part of the justification for the choice of communication

vehicles in the draft PEFCR/OEFSR.

Annex I lists examples for communication vehicles that could be used during the EF Communication

Test. Communication Testers are free to choose different communication vehicles than the

examples provided in Annex I.

Annex II contains an example of a decision matrix with preliminary reflections on the suitability of

the communication vehicles for certain situations. The matrix is provided for informative purposes

only – Communication Testers are encouraged carry out their own analysis on the suitability of

communication vehicles to their specific product or organisation.

4.1 Information to be provided by TSs

In the draft PEFCR and OEFSR the TS shall provide the following:

Identification of 3-4 communication vehicles to test;

For each vehicle proposed, justification of the choice, in particular why it is considered

effective for the given product or sector and target audience. In the justification, refer to

previous experience and studies supporting the choice, if existing.

In a separate document, the TS shall describe the modalities of the tests per vehicle tested.

Information shall include:

the type of testing (real-life purchasing situation, online simulation of real-life purchasing

simulation, focus group, other),

description of the target group,

the control groups planned/ implemented,

8 A frequent change of information could be more than once a year, which for example would have

consequences on whether the information can be displayed on supports that are meant to last longer.


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the Member States and locations where the tests will be/were carried out,

the planned/implemented measures to obtain feedback regarding the tests,

after the tests: assessment of advantages and disadvantages of the vehicles used, including

recommendations regarding which vehicles are strongly recommended or are to be avoided;

and results based on the feedback gathered by the Communication Tester.

In order to evaluate the communication tests, further information would be asked from the

Communication Testers by the Commission, which could include:

Was the communication work contracted out? If yes, what elements were implemented by

3rd parties?

How easy/ difficult was it to design the vehicle?

Did you make any adjustments to the vehicle during the testing?

During or after the test: if you had to start now, would you change your choice of vehicle

and why?

5 Implementation of communication vehicles The essential difference between communicating on PEF and OEF Profile information is the use of

information by the target audience. Whilst the audience of the PEF Profiles would be able to use this

information for choosing between available products and greening their product purchases, the

audience of OEF Profiles would use it to inform their relationship with the organisation (image,

business relations, relations with public authorities and stakeholders, etc). The OEF Profiles could

lead to choices, but it is expected that this would happen in the areas of investor relationships or

supply chain management rather than in a consumer context.

5.1 Product EF Profile information

Tests should be carried out as much as possible in real-life situations, thus as field experiments in

brick-and-mortar stores, web-stores or B2B channels usually employed by the Communication

Tester. Wherever this proves not to be feasible, online experiments simulating real-life purchasing/

contractual situations or focus groups should be used.

Interview-based approaches should always be complemented by metrics or observation of real

behaviour of members of the target group (e.g. through commercial statistics, hits to pages

containing environmental information or product pages within web-shop with environmental

information, etc.).

Communication Testers should attempt to cover an as large as possible number of representatives

from their target group with the communication test. They shall record how many people were

exposed to the vehicles tested, and, whenever possible, keep track of the features of the target

audience (age, gender, level of education, urban/rural etc). Appropriate control groups should be


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used recording the behaviour of members of the target group not exposed to the communication

testing. In case incentives are used, these shall be adequately recorded.

Communication tests should be carried out in several EU Member States where the Communication

Tester is active to allow for checking results against cultural differences and differences in the

maturity of the market of products with environmental credentials.

Communication vehicles should be operational for as a long period as possible within the pilot

period. The minimum time for which they should be in place is 6 months.

Communication Testers shall keep a record of how communication tests were implemented.

5.2 Organisation EF Profile information

Whenever OEF Profile information is provided to consumers, implementation guidance provided in

chapter 5.1 shall be followed. In such a case Communication Testers shall take special care of

avoiding confusion between product-level and organisation-level information and of avoiding to

mislead the consumer.

Tests should be carried out as much as possible in real-life situations, thus as environmental reports

or information provided to the organisation's stakeholders, covering an as wide range of them as

possible. Wherever possible, a varied group of stakeholders should be used, covering business

partners, investors, reporting initiatives, NGOs, public authorities and civil society organisations.

The sending of OEF profile information should be complemented with interviews assessing the

reaction of stakeholders to the information. Wherever possible, the behaviour of recipients should

be observed (e.g. regarding the willingness to establish contact, interest regarding the information

communicated, indications regarding a positive change in the perceived reputation of the

organisation, any influence that can be attributed to it on business/financial results, etc.). A control

group should be established in order to be able to judge the effect of the information.

Communication tests should be carried out in more EU Member States where the Communication

Tester is active to allow for checking results against cultural differences and differences in the

interest of stakeholders in environmental information.

Communication vehicles should be operational for as a long period as possible within the pilot

period. The minimum time for which they should be in place is 6 months.

Communication Testers shall keep a record of how communication tests were implemented.

5.3 Using behavioural insights for B2C communication

The key message of behavioural sciences is that human beings do not act as rationally as we tend to

think. They often take impulsive, intuitive and quick decisions. In situations such as purchasing

supplies in a supermarket, people take a lot of these quick decisions.


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As a consequence, just providing the information that could lead to a rational decision is not enough

– it is also very important how this information is conveyed, and whether this information can grasp

the attention of an "irrational" decision-maker.

The growing literature on behavioural economics9 points to essential elements for framing

communication to change behaviour. We're listing examples below which might be relevant for the

EF communication phase:

People tend to act based on what other people in their context do. A classic example in the

area of energy efficiency: adding to energy bills information on how the household's energy

efficiency compares to others in the neighbourhood generated impressive, 40% decrease in

energy use. This concept was tested and proved in several other cases.

People resist change to their routine. They tend to accept change only if it is very simple to

do so and the infrastructure or usual conditions are changed to favour changing the habit; or

in moments of transition in their lives (e.g. changing jobs, building a home, having children).

People hate to lose out on something: this is why communication on the fact that they're

losing money if they don't save energy is more effective than saying that they can gain

money by doing it. It also means that there is a high inertia, people don't like to change the

status quo, especially not for something that they suspect would lead to a worse situation.

People tend to "choose" default choices. The classic example is that of opting in or opting

out of organ donations. In case of countries where the default option is that citizens are not

donors unless they say they would like to be, the number of donors is low; in countries

where the default option is to be a donor, the number of donors is high. If there is no default

option and understanding the choices available is complicated, people tend to choose at

random or take choices based on quickly gained and imperfect information. Simplicity is

therefore extremely important.

People don't react if the cause of a problem is not visible to them in their everydays. This

issue is particularly important for environmental protection, where it is mostly impossible to

personally feel the consequences of environmental problems. E.g. it is difficult for an

individual to feel how taking the car for very short distances causes deterioration in air

quality day by day. Consequences seem distant in time and the individual feels not to have a

power over them.

People tend to react to negative messages by ignoring these. This might be particularly

important for environmental messages delivered e.g. through campaigns: messages about

the harm caused to the environment may be counter-productive, especially if people feel

that they cannot do much about it due to the scale of the problems.

Example of using behavioural insights for PEF communication

9 See the Bibliography for selected references


ver. 1.1

17

XYZ Supermarket

Well done! Your cart is greener than that

of our average buyer

PEF A Milk 1€ PEF A shoes 50€ PEF B detergent 5€

XYZ Supermarket

Your cart is less environmentally friendly than

the average buyer's cart

Milk 1€ Aggressive dishw 3.5€ PEF C T-shirt 10€ Plastic carrier bag 0.5€

XYZ Supermarket

Fantastic! Your cart is greener than that of our average green buyer!

PEF A Milk 1€ PEF A detergent refill 4€ PEF A T-shirt 10€ Glass return -5€

Which products make my cart greener? Products with an environmental footprint above C class Return policy RRRRRRRRRRR

Communication could be focussed on the person's footprint related to his/her purchases, giving

them information on how do they perform respectively to the average consumer of the shop and

respectively to the most environmentally friendly users. This could be done through their

receipts/bills. PEF information on the product/shelf could make it easy for consumers to identify

which products have a better environmental performance compared to others and thus "count"

towards greening their basket.

The front side of the receipt could look like this:

The flipside (or a flier, or other vehicle) could help consumers that get motivated to green their

purchases with tips on how to do so:

This option is based on the following behavioural concepts:

refer to what other people buying in the same supermarket do;

keep up the commitment of "green" buyers by telling them how they perform respectively

to the "best";


ver. 1.1

18

provide information on how they can improve their performance, making it easy for them to

be among the "best";

make it very easy to identify products that are more respectful to the environment and help

get out of their routine.

The limitation of the tool is that the information that might influence awareness is given mainly

post-purchase, therefore the improvement can only be seen over time and with consumers that use

the shop regularly; and that during the pilot phase the amount of products with PEF performance

information will still be limited.

Similar tools could be used to appeal to intrinsic values of people that are correlated to pro-

environmental purchasing behaviour (e.g. frugality – deals, money saving; social justice – positive

messages about contributing to social justice through their choices; health – messages regarding the

healthiness of purchases). Such factors could be used in combination with EF communication

vehicles used.


ver. 1.1

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6 Bibliography

Behavioural Insights Team UK (2012): EAST - Four simple ways to apply behavioural insights

http://www.behaviouralinsights.co.uk/sites/default/files/BIT%20Publication%20EAST_FA_WEB.pdf

Bio Intelligence Service for the European Commission (2012): Study on different options for

communicating environmental information for products

http://ec.europa.eu/environment/eussd/pdf/footprint/ProductsCommunication_Final%20Report.pd

f http://ec.europa.eu/environment/eussd/pdf/footprint/ProductsCommunication_Annex.pdf

Ecologic Institute (2014): Influences on consumer behaviour- policy implications beyond nudging

http://ec.europa.eu/environment/enveco/economics_policy/pdf/Behaviour%20Policy%20Brief.pdf

Food SCP Roundtable (2011): Communicating environmental performance along the food chain

http://www.food-scp.eu/files/ReportEnvComm_8Dec2011.pdf

Joint Research Centre (2013): Applying behavioural Sciences to EU policy-making

http://ec.europa.eu/dgs/health_consumer/information_sources/docs/30092013_jrc_scientific_polic

y_report_en.pdf

Ministère de l'Ecologie, du Développement durable et de l'Energie (2013): Bilan au Parlement de

l'experimentation national – Affichage environnemental des produits de grande consommation

http://www.developpement-durable.gouv.fr/Bilan-au-Parlement-de-l.html

MORI, London Economics and AEA for the European Commission (2012): Research on EU product

label options

http://ec.europa.eu/energy/efficiency/studies/doc/2012-12-research-eu-product-label-options.pdf

Report of the Multi-stakeholder Dialogue on Environmental Claims (2013), presented at the

European Consumer Summit in March 2013

http://ec.europa.eu/consumers/events/ecs_2013/docs/environmental-claims-report-ecs-

2013_en.pdf

UK Cabinet Office, Behavioural Insights Team (2011): Behaviour change and energy use

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/60536/behaviour-

change-and-energy-use.pdf

http://www.behaviouralinsights.co.uk/sites/default/files/BIT%20Publication%20EAST_FA_WEB.pdf



http://ec.europa.eu/environment/eussd/pdf/footprint/ProductsCommunication_Annex.pdf

http://ec.europa.eu/environment/enveco/economics_policy/pdf/Behaviour%20Policy%20Brief.pdf

http://www.food-scp.eu/files/ReportEnvComm_8Dec2011.pdf

http://ec.europa.eu/dgs/health_consumer/information_sources/docs/30092013_jrc_scientific_policy_report_en.pdf

http://ec.europa.eu/dgs/health_consumer/information_sources/docs/30092013_jrc_scientific_policy_report_en.pdf

http://www.developpement-durable.gouv.fr/Bilan-au-Parlement-de-l.html

http://ec.europa.eu/energy/efficiency/studies/doc/2012-12-research-eu-product-label-options.pdf



https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/60536/behaviour-change-and-energy-use.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/60536/behaviour-change-and-energy-use.pdf


ver. 1.1

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Annex I – Examples of communication vehicles

The examples of communication vehicles provided below are not meant to be exhaustive: their role

is to provide ideas to identify what might work for the Communication Testers' product or

organisation. Communication Testers are free to identify additional communication vehicles and

design the communication vehicles as they see appropriate.

Communication vehicles shall in all cases respect the general principles laid down in this document.

Tables below identify some specific requirements to individual communication vehicles based on

literature and the general principles.

The examples provided in the tables are illustrative only – in some cases they may not fulfil the

requirements of the EF Pilot Phase (e.g. a carbon reduction label would not be acceptable during the

pilot, as it doesn't satisfy the requirement of completeness, therefore it is there only to illustrate the

meaning of the concept).

1. PEFCRs

A. At the Point of Sale (POS)

In this case, the medium for communicating the PEF profile is available at the Point of Sale (POS).

Thus, it is on the packaging of the product or attached to it; is available near the product, e.g. on the

shelf; or is available on devices that are meant to be used at the POS.

In case of web-shops , Communication testers shall display the environmental information together

with the product in the web-shop (e.g. include an electronic version of the label on the product's site

on the shop).

Performance label

According to several studies, performance scales (e.g. A-G, A

representing the best performing product) are well understood

by consumers. Consumers do trust absolute values (e.g. "15g

CO2"), however they like to see these positioned on a

performance scale. Consumers would like to see how the

product performs on a maximum of 3 important indicators, but

also prefer to see an aggregated indicator on the overall

performance of it.

Performance labels shall:

be based on the benchmark and performance scales

defined in the PEFCR;


ver. 1.1

21

depict all the possible performance scales, identifying

clearly which is the performance of the product;

identify at least the letter (or other scale) for signalling

the environmental performance of the product on a

maximum of 3 impact categories;

base the impact categories listed on the identification of

the most important environmental impact categories

and life cycle stages of the draft PEFCR;

provide information on whether the information was

verified.

Furthermore, during the design of the label, Communication

testers should consider the specificities of the product (e.g.

readable in black-and-white for products where labels in colour

are not used).

Performance label + QR code

This solution combines performance scales (individual and

overall score) and the possibility to provide additional

information via websites or apps. This opens the possibility to

link further information both on how the information was

generated and on more environmental performance details

directly to the product.

Requirements related to the performance label apply.

Performance improvement

label

This vehicle may be used in cases where the PEFCR concludes

that it is not feasible to establish a benchmark and performance

classes for the given product. In this case, the information

provided shall not suggest a comparison between different

products, but it shall convey information on how the product

perfoms respectively to a previous point in time. The period

concerned shall be defined in the PEFCR.

As for other labels and communication vehicles, information shall

be available on how the results calculated based on the PEFCR

and the PEF Profile and shall include information on 3

environmental impact categories and could include an indicator

on overall performance.


ver. 1.1

22

Barcodes

By using attributes tied to a barcode, provide PEF profile by the

reading of the barcode.

In case it is used in a B2C context, additional development is

necessary to make the information understandable by the

consumer (e.g. information on apps, websites, self-scan

terminals and/or receipts).

The European Commission has an agreement with GS1, the non-

profit organisation providing barcodes to implement a test node

for the EF pilot. The possibility to use bar codes will be

considered by GS1 on a case-by-case basis. There might be a limit

as to how many test cases GS1 can accept.

On-shelf information Information provided on the shelf where the product is

displayed, typically placed on or around the price tag. It is

particularly suitable for products without packaging (e.g. loose

vegetables and fruit, individual envelopes, etc.), guaranteeing

that complementary information is available on other vehicles.

Pictogram

E.g. instructions regarding the use of the product in order to

ensure a lower environmental footprint in the use stage. It may

be combined with information on how much the user can lose

(or save) in case they use the product in a correct way.

This solution may be considered only where the performance

level of the product depends greatly on the behaviour of the

user; and where additional vehicles are used to communicate

further information.

POS product advertisement

This is a group of vehicles for materials used in stores, for

example:

in-store signs or advertising drawing attention to a

selection of products with a PEF profile;

sample distribution or tastings.

These vehicles may be used in combination with other vehicles

conveying environmental performance information based on the

PEF Profile.


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Declaration/ product passport

(B2B)

The PEF profile can be communicated through a PEF declaration which is intended to be either publicly available or not. The PEF declaration shall be based on the PEFCR for that product category and should be supported by a specific PEF study.

The PEF declaration should include:

a) Identification and description of the organization making the declaration,

b) Product identification (e.g. trade name, model number, other common names of the product, the Global Trade Item Number),

c) Description of the function, technical performance, intended use of the product, expected service life time, etc,

d) Characteristics of the product relevant to the specification of the delivery or unit of analysis: dimensions, mass, physical and chemical properties,

e) Description of the final application, if it is an intermediate product,

f) PEFCR identification, g) Date of publication and period of validity of the

declaration, h) Results of the PEF calculation at least for the EF impact

categories identified as relevant in the PEFCR, i) Additional environmental information, j) information about substances to be declared (content,

emissions) as necessary to allow risk assessment, k) Information on which life cycle stages are not

considered, if the declaration is not based on an PEF study covering all life cycle stages,

l) Statement that environmental declarations from different programmes may not be comparable,

m) Web site address where explanatory material and all supporting information related to the calculations done is available,

n) Information about the verification. With appropriate justification, requirement j) does not apply to


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proprietary information relating to materials and substances

covered by intellectual property rights or similar legal

restrictions. It may also not be appropriate for declarations

concerning intangible products.

Regarding point h), reporting results include a weighted single

score as defined in the PEFCR, and performance values, where

feasible.

If relevant, the issuer of a declaration might decide to provide

additional product information that is relevant for the

environmental performance of the product during its further

transformation and use; and information on performance

improvements in the product over time.

Co-existence with existing labels or certifications

The EF Communication Test is a temporary exercise that aims to test labels and other vehicles. It

being temporary and a test it is not intended to contribute to the proliferation of labels and other

information - on the contrary, it aims to gather learnings to help reduce proliferation in the future.

Communication on the PEF Profile will unavoidably happen in the context of already existing labels

and product information. Some of this information is communicated on a voluntary basis (e.g.

ecolabels), some others are mandated (e.g. energy label). Literature warns of the risk of

overburdening consumers with information and creating confusion through the variety of

information available. It is clear already now that future policies will have to prioritise coherence and

interplay with existing labels and well-established vehicles. Inputs from the communication phase of

the EF pilots might provide further insight on potential solutions.

Communication Testers will also face this issue for their products included in the EF Pilot. They

should discuss this issue, propose and test solutions. Communication Testers have full flexibility

regarding this aspect, as long as legal requirements related to existing vehicles are respected.

Examples given below are only intended as rough ideas.

Existing certification on e.g. sustainable forest management/

fishing, etc.: The PEFCR has the role to identify environmental

impacts that are relevant for a given product category, including

in terms of additional environmental information. In cases where

the PEFCR points to non-LCA impacts covered by existing

certification schemes (e.g. forest management turns out to be an

important issue that determines the overall environmental

performance of the product), the issue of how to include existing

certifications in the EF Profile communication arises.


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XYZ Supermarket

Fantastic! Your cart is greener than that of our average green buyer!

PEF A Milk 1€ PEF A detergent refill 4€ PEF A T-shirt 10€ Glass return -5€

Organic farming: for products issued from agriculture, consumers might perceive

the organic logo and the PEF Profile as conflicting. An attempt should be made to

present the two information in a complementary manner, e.g. by including information on

regarding the type of farming into additional environmental information and displaying this

information within the PEF Profile.

Energy label: there is no issue of co-existence with the energy label, because none of the

products in the pilots have EU energy labels. Note that there are restrictions on using labels

with a similar layout as the EU energy label as explained in the Frequently Asked Questions

document on the Energy Labelling Directive

(http://ec.europa.eu/energy/efficiency/labelling/doc/2013_labelling_faq.pdf).

B. Close to the POS

Consumer receipt – basket

comparison

Providing the environmental performance of the basket of

products bought by the consumer on the receipt. In case of web-

shops similar information could be provided at checkout or sent

as part of a confirmation e-mail.

See more detailed explanation and example on this possibility in

the section "Using behavioural insights for B2C communication".

On invoices (B2B) Among the features of the product communicated on the

invoice, include PEF Profile information. A total "basket"

performance may also be communicated, and eventually

complemented with information on whether the buyer belongs

to the "greener" or "average" customer group.

Loyalty schemes Use existing loyalty schemes to direct consumers towards

greener choices e.g. by awarding extra loyalty points or awarding

products with PEF Profile as a premium for points.

This vehicle may be used in combination with other vehicles that

convey information on the PEF Profile of the product.

Printed information material This vehicle may be used in cases where the decision of purchase

http://ec.europa.eu/energy/efficiency/labelling/doc/2013_labelling_faq.pdf


ver. 1.1

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(leaflets, catalogues, etc.) is not immediate – where it is expected that consumers "look

around" and take a decision later (and not at the POS) regarding

the purchase (e.g. paints, kitchen furniture, vehicles).

PEF Profile information may also be integrated into already

existing sales folders/catalogues used in B2B or regularly

distributed sales publicity material used in B2C.

C. Beyond the POS

Instruction manuals

Instruction manuals include details on the PEF Profile of the

product and instructions regarding the use of the product while

minimising the environmental footprint.

This solution could be most appropriate where the performance

level of the product depends on how the product is used.

Websites (producer, vendor)

Information provided on the environmental performance of a

product on the producer's or vendor's website. This

communication shall follow similar principles as those used for

labelling.

As opposed to labels, this vehicle enables to include more

information for interested consumers and point in an easy

manner towards well-performing products.

Websites (3rd party)

Websites specialised on providing environmental information on

products operated by 3rd parties (e.g. NGOs, companies

specialised on providing information).

Such channels may be used in cases where PEF Profile information

is accepted by the 3rd party as a proof of the environmental

performance of the product. PEF Profile information may be used

in combination with other information (e.g. social information) if

requested by the 3rd party, however, all misunderstanding shall be

avoided regarding to what the PEF Profile and its verification

covers.


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App based on performance

Through barcodes or QR codes it is possible to link to this

information from the packaging of the product and provide

product-specific environmental performance information at any

time.

Examples exist where similar products are also displayed which

have a better environmental performance (e.g. QuestionMark).

Label-related specific requirements apply.

Campaigns targeting user

behaviour

This tool is particularly relevant for products where the use and

EoL stage turns out to be among the most important life cycle

stages for the given product.

In such a case, the following further conditions apply for the use

of this vehicle:

the campaign shall reflect the environmental impacts

identified as relevant for the given product;

it may be regarded as a self-standing vehicle only in case

the use and EoL stages are providing the overwhelming

majority of environmental impacts;

in case the use and EoL stages prove to be one of the

most important life cycle stages, it shall be used in

combination with (an)other vehicle(s) to guarantee the

completeness of the information.

Marketing campaigns/

advertising

In this case PEF Profile-based information is presented as a part of

a product campaign through any media (TV, radio, print, online).

Due to the nature of the tool, information presented may contain

partial PEF Profile information, however, the campaign shall

include the means on how to get the complete information

corresponding to the general principles laid down in this

document.

PEF external communication The PEF external communication report shall include all reporting elements indicated in chapter 8 of the PEF Guide. The


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report (B2B) Technical Secretariat shall propose and justify any deviations from the default reporting requirements, and any additional and/or differentiating reporting requirements that depend on, for example, the type of applications and the type of product being assessed.

The PEFCR shall specify whether the PEF results shall be reported separately for each of the selected life cycle stages.

Performance tracking report

(B2B)

PEF communication may take the form of a PEF performance tracking report, which allows for the comparison of a PEF profile of a specific product over time with respect to its original or previous PEF profile.

The communication of the performance tracking report shall be based on a specific PEF study and PEFCR requirements for that product category (if existing). When communicating a change in a PEF profile to the public, the main contributions to the change shall be specified.

Communication of performance tracking may be made when they are due to:

a) Improvements made by the reporting organization, b) Selection of other suppliers, c) Deliberate and verifiable improvements made by

suppliers, d) Improvements in the use stage and in the endoflife

stage made by improved product design or an improved end-oflife procedure,

e) Changes due to process improvements. Changes due to seasonal changes10 or finding better secondary data sources shall not be reported as performance changes.

The communication may be supported by a graphical representation of the processes in the life cycle of the product, which allows an understanding of the system boundary, the contribution to the PEF profile and the changes included.

2. OEFSRs

A. Report and related

OEF external communication The OEF external communication report shall include all

reporting elements indicated in chapter 8 of the OEF Guide,

10

Seasonal changes are e.g. seasonal variation in sales of a product that can impact production rate and hence

efficiency of the production plant, seasonal variation in agricultural production.


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report

whether used as part of a sustainability report or as a self-

standing report. In case OEF Profile information is provided

based on a stakeholder or investor questionnaire, the template

provided by the investor may be used, however indications shall

be provided to where complementary information can be found.

The Technical Secretariat shall propose and justify any deviations

from the default reporting requirements, and any additional

and/or differentiating reporting requirements that depend on,

for example the type of organisation being assessed.

The OEFSR shall specify whether the OEF results shall be

reported separately for each of the selected life cycle stages.

OEF performance tracking

report

OEF communication may take the form of an OEF performance

tracking report, which allows for the comparison of an OEF

Profile of the same organisation over time with respect to its

original or previous OEF Profile.

The communication of the performance tracking report shall be

based on a specific OEF study and OEFSR requirements for that

sector (if existing). When communicating a change in an OEF

Profile to the public, the main contributions to the change shall

be specified.

For example, communication of performance tracking may be

made when they are due to:

a) Improvements made by the reporting organisation; b) Selection of other suppliers; c) Deliberate and verifiable improvements made by

suppliers; d) Improvements in the use stage and in the endoflife

stage made by improved product design or an improved end-oflife procedure;

e) Changes due to process improvements. Changes due to seasonal changes11 or finding better secondary

data sources shall not be reported as performance changes.

The communication may be supported by a graphical

representation of the processes in the life cycle of the

organisation’s product portfolio, which allows an understanding

of the system boundary, the contribution to the OEF Profile and

11

Seasonal changes are e.g. seasonal variation in sales of a product that can impact production rate and hence

efficiency of the production plant, seasonal variation in agricultural production.


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the changes included.

As part of an environmental,

sustainability or integrated

report

The information is presented as part of an environmental report

(e.g. in the framework of an environmental management system

such as EMAS or ISO14001) or as a part of a wider report,

together with other environmental information. The information

presented may be either the OEF Profile or performance tracking

information, or a mix thereof.

Environmental / sustainability

rankings or indices (3rd party)

OEF-Profile based information provided to sustainability or

environmental performance ranking organisations/websites.

Such channels may be used in cases where OEF Profile

information is accepted by the 3rd party as a proof of the

environmental performance of the organisation. OEF Profile

information may be used in combination with other information

(e.g. social information) if requested by the 3rd party, however,

all misunderstanding shall be avoided regarding to what the OEF

Profile and its verification covers.

OEF Profile information may also be provided only partially, with

the condition that the availability of further information is clearly

indicated and accessible.

Reporting initiatives (3rd party)

OEF-Profile based information provided to reporting initiatives

that gather environmental and/or sustainability performance

information on companies. It is of interest for the EF Pilots to find

out how OEF Profiles match or complement information

requested by existing reporting initiatives such as the CDP or GRI.

Such channels may be used in cases where OEF Profile

information is accepted by the 3rd party as a proof of the

environmental performance of the organisation. OEF Profile

information may be used in combination with other information

(e.g. social information) if requested by the 3rd party, however,

all misunderstanding shall be avoided regarding to what the OEF

Profile and its verification covers. OEF Profile information may

also be provided only partially, with the condition that the

availability of further information is clearly indicated and

accessible.

B. B2C vehicles

As a general requirement, any B2C communication on OEF Profiles shall be very carefully designed,

and any confusion between product-specific and organisation level information avoided.


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POS communication related to a

group of products

The group of products shall be defined based on the product

portfolio (or sub-portfolio) to which the OEFSR relates.

The communication on the environmental performance of the

portfolio may also take the form of a description. If such claims

are made, details at the basis of the claim shall be available to

the consumer (e.g. on a website, app, leaflet, etc.) and the claim

shall be verifiable based on the OEF Profile results. Best practice

related to green claims shall be respected, including the

avoidance of vague or non-specific terms12.

Environmental campaigns

The use of this tool is justified in case the use stage or EoL is

particularly important for the good environmental performance of

the product portfolio. It shall be used in combination with other

vehicles in order to ensure that the general principles are met.

Public Relations Public Relations efforts based on OEF Profile results, used as a

reputational tool. This tool may only be used in combination with

other OEF communication vehicles.

Claims made within the PR effort shall respect the general

principles laid down in this document.

12

European Commission Guidelines for Making and Assessing Environmental Claims (2000)


2009 Guidance on the implementation/application of directive 2005/29/EC on unfair commercial practices,

Chapter 2.5 Misleading environmental claims

(http://ec.europa.eu/consumers/rights/docs/Guidance_UCP_Directive_en.pdf)

Environmental Claims - Report from the Multi-Stakeholder Dialogue, 2013



http://ec.europa.eu/consumers/rights/docs/Guidance_UCP_Directive_en.pdf



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Annex II – Decision matrix for the choice of communication vehicles

PEFCR based communication

Decision point

Perfo

rman

ce label

Perfo

rman

ce + value

label

Perfo

rman

ce label +

QR

cod

e

Perfo

rman

ce

imp

rovem

ent lab

el

Picto

gram

Barco

des

On

-shelf in

form

ation

Instru

ction

man

uals

PO

S pro

du

ct

advertisem

ent

Declaratio

n/ p

rod

uct

passp

ort

Co

nsu

mer receip

t

Invo

ices

Loyalty sch

emes

Prin

ted in

form

ation

m

aterial

Ow

n w

ebsites

3rd p

arty we

bsites

Ap

p b

ased

on

perfo

rman

ce

Enviro

nm

ental

camp

aigns

Marketin

g camp

aigns/

advertisin

g

PEF extern

al co

mm

un

ication

repo

rt

Perfo

rman

ce tracking

repo

rt

(Target) B2C X X X X X X X X X X X X X X X X X

(Target) B2B X X X X X X X X X X X X X

(Target) public procurers X X X X X X X X X

(Comparability) Yes X X X X X X X X X X X X X X X X X X

(Comparability) No X X X X X X X X X X X X X X X X X

(Life cycle) Use/EoL

overwhelming X X X X X X X X X X X

(Life cycle) Use/EoL important X X X X X X X X X X X X X X X X X X X X X

(Life cycle) Cradle-to-gate

overwhelming X X X X X X X X X X X X X X X X X X X

(Vehicle use) Self-standing X X X X X X X X X X X X

(Vehicle use) In combination X X X X X X X X X X

(Purchase) On-spot decision X X X X n.a. X X n.a. X n.a. n.a. n.a. X X X X n.a. n.a.

(Purchase) Deferred decision n.a. n.a. X X X X X X X X n.a. n.a.

(Updates) Frequent n.a. X X n.a. X X X X X X n.a. n.a. X X


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(Updates) Yearly or more X X X X n.a. X X X n.a. X x x X X X X X n.a. n.a. X X

(Cost) High/ difficult access

Case specific: to be filled out when data is available/ the vehicles are defined more in detail

(Cost) Low/ easy access

Other specificities

(Final check) Conform

(Final check) Not fully conform


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OEFSR based communication

Decision point

External

com

mu

nicatio

n

repo

rt

Perfo

rman

ce trackin

g rep

ort

Part o

f su

stainab

ility/ in

tegrate rep

ort

Ran

kings/

ind

ices

Rep

ortin

g

initiatives

PO

S for gro

up

s o

f pro

du

cts

Enviro

nm

ental

camp

agns

Pu

blic relatio

nsh

(Target) B2C X X X

(Target) B2B X X X X X X

(Target) public procurers X X X X X X

(Comparability) Yes X X X X n.a. X X

(Comparability) No X X X X n.a. X X

(Life cycle) Use/EoL overwhelming n.a. n.a. n.a. n.a. n.a. X X n.a.

(Life cycle) Use/EoL important X X X X X X X X

(Life cycle) Cradle-to-gate overwhelming X X X X X X X

(Vehicle use) Self-standing X X X

(Vehicle use) In combination X X X X X

(Updates) Frequent X X X X

(Updates) Yearly or more X X X X X X X X

(Cost) High/ difficult access

Case specific: to be filled out when data is available/ the vehicles are defined more in detail

(Cost) low / easy access

Other specificities

(Final check) Conform

(Final check) Not fully conform

background document for the testing of...

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