Type I labels are governed by ISO standard 14024:2018 Environmental labels and declarations – Type I environmental labeling – Principles and procedures. These labels communicate that a particular product or service meets or exceeds specific and quantitative environmental criteria set by independent third-party organizations. As such, Type I labels require third-party verification, which makes them a credible and useful means of “narrowing down” your long list of potential products or services. However, attaining these labels can be cost-prohibitive for suppliers, especially if they have many products in different categories. This helps explain why few products have them. Some examples of Type I labels are shown in Figure 2.

In the case of Energy Star, it verifies the efficiency of different product categories. For example, if someone were seeking an efficient uninterruptible power supply (UPS), they could use the Energy Star product finder to search for the most efficient UPS within a given topology. While Type I labels provide a convenient and valid means of comparing certain product attributes, like efficiency, they aren’t based on a lifecycle assessment (LCA).

Figure 2 - Examples of Type I labels

Type II labels are governed by ISO standard ISO 14021:2016 Environmental labels and declarations – self-declared environmental claims (Type II environmental labeling). Like Type I labels, they communicate that a product or service meets or exceeds specific and quantitative environmental criteria. However, as the title implies, these labels are self-declared, meaning that a product manufacturer can apply whatever claim they wish without third-party verification. Unfortunately, less reputable manufacturers take advantage of this and make false claims on their Type II labels. Therefore, due diligence is imperative if you want to use Type II labels in your assessment. It’s important that the manufacturer provide the underlying documentation of their labeling program along with the data. According to ISO 14021, “The evaluation methodology used by those who make environmental claims should be clear, transparent, scientifically sound, and documented.” In addition, the manufacturer should have the data available to substantiate the claim. The label should not imply that the product is certified or otherwise validated by a third-party. An example of a Type II label is shown in Figure 3.

Figure 3 - Example of a Type II label

Type III labels are governed by ISO standard ISO 14025 Environmental labels and declarations –  principles and procedures (Type III environmental declarations). In simple terms, an environmental product declaration (EPD) is a document that summarizes the environmental life cycle data of a product or service and is normally valid for 5 years. EPDs help specifiers make product decisions based on that product’s environmental sustainability. This is similar to the nutrition facts label you see on food products which help us decide which food to buy. The main reason why food labels help shoppers compare similar foods is because the labels (in their respective countries) are standardized. Similarly, EPDs help specifiers more easily compare products in the same category, like a circuit breaker. The ISO 14025 standard “establishes the principles and specifies the procedures for developing Type III environmental declaration programs and Type III environmental declarations.”

EPDs must be based on LCA data or lifecycle inventory analysis data, which are themselves governed by the ISO 14040 standard. It’s important to note that ISO 14040 is generic and applies to all types of products and services, and therefore, it isn’t very useful for a specific product category. Program operators help fill this gap by administering programs in compliance with ISO 14025 so that EPDs report the same type of information.

According to ISO 14020, a program operator can be “a company or a group of companies, an industrial sector or trade association, public authorities or agencies, or an independent scientific body or other organization.” The program operator develops, approves, and publishes product category rules (PCR) and product specific rules (PSR) (see end note 5). PCRs are a “set of specific rules, requirements, and guidelines for developing Type III environmental declarations for one or more product categories” (see end note 6). For example, the PCR related to this paper covers electrical, electronic, and HVAC-R products and defines how manufacturers should perform the LCA. The PSRs define rules for specific products within this category, like a circuit breaker, air conditioner, UPS, etc. Program operators also manage the registration and publication of the EPDs and try to ensure that manufacturers don’t receive an unfair advantage by bending the rules when creating their EPD. We discuss some of these pitfalls in the “guidance for accurate product comparisons” section.

ISO 14040 Table A.1 provides a summary of the steps and bodies involved in the development and operation of an environmental declaration program. Figure 4 illustrates this and shows that interested parties are part of the process. The standard states that “interested parties may include material suppliers, manufacturers, trade associations, purchasers, users, consumers, non-governmental organizations (NGOs), public agencies and, when relevant, independent parties and certification bodies.”

We provide EPDs called product environmental profiles (PEP). PEP is the term used by the program operator, the P.E.P. Association, which administers the PEP ecopassport Environmental Declaration Program. This program operator supports PCRs for EEE and HVAC products. Note that product manufacturers typically develop their EPDs per the program operator’s rules, but they must be independently verified by either internal (see end note 7) or external experts as disclosed in the EPD documentation. While EPDs make it easier for you to quantify the environmental sustainability of different products, they also provide the information companies need to account for their Scope 1, 2, and 3 emissions to show their progress against their corporate environmental goals. Figure 5 provides an example PEP for an arc fault detection circuit breaker.

In summary, Type III labels, i.e., EPDs, are a key tool to quantitatively assess a product’s environmental impact. These documents are based on ISO standards and validated. Manufacturers should make their EPDs freely available. Type I labels are third-party verified and useful for specific performance measures like energy efficiency. Lastly, Type II labels can be helpful if the manufacturer provides the underlying documentation which provides its credibility.

This is the product upon which the sustainability information is modeled and forms the basis for your comparison. A description of the product may also be included. EPD rules allow this reference product to represent all of the models in a product range. Later, we’ll discuss how you can use the reference product’s data to estimate your target model’s data.

This states the function of the representative product. For example, “to step down a distribution line voltage of 75kVA to voltage levels used by the end customer at the energy efficiency requirements defined by the DOE (Department of Energy) for 20 years.” Sometimes the functional unit is stated per unit energy, per unit weight, etc. Note that to compare two PEPs, the functional unit and assessment methodology must be the same. See the “guidance for accurate product comparisons” section for more information.

This provides the reference product’s weight as well as a percentage breakdown of its materials, including packaging. The total weight is used to proportionally scale the environmental data for a different model.

This provides information on the reference product’s manufacturing, distribution, installation, use, and end of life as it pertains to its lifecycle analysis. These are some of the assumptions that were used in the LCA.

This section opens with some more LCA assumptions. Figure 6 shows an example of these assumptions in an environmental impacts table for an electrical busway. The last row in the table is especially important since it conveys the emission factor (see end note 8) used in the LCA. We discuss this important assumption in the next section.

The table is followed by a list of “impact indicators” for the reference product, which measure the environmental impacts of a product. These values are usually listed in scientific notation (e.g., 2.52E+02). One key environmental impact indicator is:

• “Contribution to global warming” or “global warming,” typically in units of kg CO2e (“e” stands for equivalent). This is what most people refer to as a product’s “carbon footprint.”

This and other impact indicators are given for each of the five LCA stages, defined in the PCR as:

• Manufacturing – “from the extraction of natural resources to product and packaging manufacturing and their delivery to the manufacturer's last logistics platform”;
• Distribution – “transportation from the last manufacturer's logistics platform to the arrival of the product at the place of use”;
• Installation – “installation of the product at the place of use”;
• Use – “use of the product and maintenance necessary to ensure the ability for use”;
• End-of-life – “removal, dismantling, and transportation of the end-of-life product to a treatment center or landfill site, and the end-of-life treatment”.

The last section of the PEP is presented as a table that includes:

• The date the PEP was issued;
• The validity period;
• The PSR and version on which the PEP is based;
• Independent verification of the declaration and data; the “X” indicates whether the PEP is based on internal or external verification.

PEP data is not precise. Therefore, if the values of a particular indicator are within 10% of each other, the two products should be considered equal for that indicator. This is due to the +/- 5% margin of error that the standards allow for a manufacturer’s reported values. For example, if the carbon footprint of product “A” is 100 kg, and product “B” is 105 kg, they should be considered equal because their “+” and “–” ranges overlap.

PEP documents contain a lot of data, some of which is complex. Therefore, PEP documents should provide a link to definitions of the terms used within them. This is even more important when comparing products from different manufacturers because the definitions provide validation that you’re comparing the same type of data.

Comparing the total footprint doesn’t ensure that you’re comparing like-for-like values unless each LCA stage is assessed the same way. The next bullet demonstrates the importance of this.

All electrical products have electrical losses, which generate carbon emissions. However, the magnitude of these emissions is highly dependent on the emission factor, which is the ratio of greenhouse gases emitted for every kWh of electricity generated. An LCA assumes a certain emission factor to calculate the carbon emissions generated during the product’s “use” stage.

If the emission factor is not the same between the products you’re comparing, you can’t fairly compare them. This is especially important for active electrical products like air conditioners and UPSs since the emissions during the use stage typically represent the majority of the total LCA emissions. For example, it’s quite possible for a PEP of an efficient UPS (e.g., 95%) to show total emissions three times higher than a grossly inefficient UPS (e.g., 80%). As shown in Table 1, this example was calculated assuming an overall emission factor for the 27 European countries (0.231 kg CO₂e/kWh) compared to the emission factor for France (0.062 kg CO₂e/kWh). While this doesn’t appear to be fair, program operators do allow manufacturers to use specific country emission factors for models sold in that country. However, in some cases, these same models are sold globally as well.

Furthermore, the PEP’s “energy model used” (last row in Figure 6) makes it difficult to ascertain the emission factor because it’s usually stated in terms of an electricity mix code such as “<1 kV; EU-27.” If you’re unable to ascertain the emission factor for all products, the most effective way of assessing the use-stage emissions between two or more products is to compare their efficiencies at the same load using efficiency calculators. For example, the “Single-phase UPS Efficiency Comparison Calculator” provides an effective and simple way of comparing the efficiency of two different UPSs. Note that while this method won’t account for the maintenance emissions of the use stage, it can be ignored for certain products like UPSs since it represents a trivial percentage of total use (<2%).

Finally, if efficiency calculators aren’t available for the product you’re comparing, it’s best to ask the manufacturer to provide the efficiency curve for the product, which allows you to compare the efficiency of all products at the same load percentage.

Key takeaway: If the emission factor is not the same between the products you’re comparing, you can’t fairly compare them.

A use profile prescribes the percentage load and length of time a representative product operates during its lifetime (fourth row in Figure 6). For example, a use profile may specify 25% loaded for 20% of the lifetime, 50% loaded for 20%, 75% loaded for 30%, and 100% loaded for 30%. The use profile is used to calculate the carbon emissions discussed in the previous bullet. If the use profiles are different, the values can’t be compared. Finally, the use profiles are based on specific modes of operation (e.g., normal mode, economizer mode), and these modes must also be consistent in product comparisons.

PEP rules allow reference products to represent models in a product range. Directly comparing reference products from two or more PEPs may mean that you’re comparing the carbon footprints of products with different capacities (e.g., 100A breaker vs. 600A breaker) - an invalid comparison. Sometimes, like in the case of air conditioning equipment, the PEP provides the environmental impact indicators in normalized units (e.g., kg CO2e per kW of cooling). If the indicators aren’t normalized, you must proportionally scale the environmental indicator of the reference product using its weight (e.g., manufacturing emissions kg per kg of reference product weight). Similarly, you must proportionally scale the use data of the reference product using its rated power capacity (e.g., use emissions kg per watt of reference product capacity). Table 2 provides an example of how to calculate the manufacturing emissions for “Model B,” the model you want to assess, by using “Model A”, the reference product in the PEP.

You must repeat this process for each environmental indicator you want to assess. These extrapolations fall within the expected accuracy of the PEP data.

PEPs with different PSR and PCR versions may introduce variances that invalidate the comparison. Check the table on the last page to verify the same PSR and PCR versions.

We don’t recommend comparing EPDs from different program operators (e.g., one from the P.E.P. Association and one from Ecoleaf). This is mainly because the PCRs upon which the lifecycle analyses are based are likely different. The proliferation of program operators (see end note 9) over the years, especially in the building and construction materials industry, has led to various efforts to harmonize PCRs. But to date, there’s no single organization ensuring PCR consistency across program operators.

PCR edition four includes an additional stage referred to as Module D, “net benefits and loads beyond the system boundaries.” This optional stage allows manufacturers to claim an environmental credit for “reuse, recovery, and/or recycling.” For example, if 100% of a product was recycled, the manufacturer would claim a negative value equivalent to the manufacturing footprint. This is only valid if the manufacturer has a recycling program that recycles 100% of every end-of-life product to be used as raw materials. The recycling program must also apply to your location. Before blindly accepting this credit, ask the manufacturer for detailed information on their recycling program, with specific attention to how they ensure that 100% of the products are returned to them and don’t end up in a landfill.

Sometimes PEPs exclude components that one would expect, thereby setting the expectation that one manufacturer has a significantly lower footprint than another. For example, a UPS PEP may exclude batteries. In most cases, switchgear or electrical panel PEPs exclude circuit breakers. To prevent this mistake, read through the entire PEP and note what’s excluded.

This is the ability for a product “to exist for a long time without significant deterioration in quality or value.” In essence, the longer a product performs its mission with minimal maintenance and degradation, the more sustainable it is (assuming it’s also efficient and relevant). When you prolong the need to replace the product, you defer the associated resources required to manufacture it, distribute it, and the impact of disposing of the old product. Modularity can be an effective design approach to improve durability in two related ways. First, when a product is modular, you can repair the failed module by swapping it out with a new one rather than replacing the entire product. Second, standardized modules allow manufacturers to quickly improve module reliability compared to an equivalent non-modular product. This means that fewer repairs are needed, and consequently, less waste ends up in landfills. Examples of modular products include draw-out switchgear and scalable UPS systems (swappable power and battery modules).

For products with components that are “consumable” (e.g., air filters), durability also implies that the manufacturer will offer replacement parts and maintenance services for the life of the product. With this information, decision-makers can be more confident in choosing products with a lower total cost of ownership (TCO), especially in cases where one product’s upfront cost is much less than the other. Durability assessment is based on standards such as European Standard CSN EN 45552, the general method for the assessment of the durability of energy-related products.

This describes the extent to which a product is repairable. Like durability, repairing a product allows it to stay in service longer, thereby improving its sustainability. Repairability is covered by European standard CSN EN45554, “General methods for the assessment of the ability to repair, reuse, and upgrade energy-related products.” Repairability also speaks to the ease of repairing the product. For example, in the case of switchgear, repairability is significantly improved with modular components. Other examples include the use of software to alert the user of which sub-system has failed, the use of standardized parts and fasteners, and the ease of access to the most frequently replaced parts.

This describes the possibility of sending an end-of-life product back to the manufacturer, either directly or through a service provider. The goal of take-back is to extract the maximum value out of end-of-life products versus throwing them into a landfill, which leads to more wasted resources. When manufacturers make it easy to take back an end-of-life product, it greatly increases participation in 5R programs (repair, refurbish, remanufacture, reuse, and recycle), giving manufacturers more options to extend the life of existing products by increasing inventories of spare parts and refurbished units. Those products or components which are not recoverable can then be properly recycled.

In order for a product to claim “take-back” performance, the manufacturer must approve the product for return to one or more of its service providers. This means that the manufacturer has developed a process for end-of-life returns between the user and service providers, or directly to the manufacturer’s facilities. This also means that the personnel receiving the products are trained in processing them. Returning an end-of-life product may also qualify the user for upgrades to new products.

The program provides more transparent data covering the entire product lifecycle. This detailed product environmental information goes beyond existing regulatory requirements in response to customers' growing expectations.

The program includes five data categories, each corresponding to a product lifecycle stage. With over thirty data points with tooltips, you can easily understand the Environmental Data Program and make informed decisions.

The program empowers you to make fact-based decisions leveraging reliable and granular lifecycle-related data points. You will be able to differentiate your own value proposition by opting for more sustainable choices, and accurately evaluate and report on your own environmental footprint and CO2 emissions reduction efforts.