November 20, 2013 PUBLIC COMMENTS SOUGHT: 

Draft Guidelines for Product Environmental Performance Standards & Ecolabels for Voluntary Use in Fede

DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & ECOLABE

# Guideline Name Guideline B/L Sour

Section I: Guidelines for the Process for Developing Standards

1 Open Participation Reasonable efforts were made to ensure participation was open to all directly and materially affected 

persons. There was no undue financial barrier for participation. 

B ANSI E

Requi

2 Voting Open Voting membership on decision-making body was not conditional upon membership in any organization. L ANSI E

Requi

3 Reasonable Voting 

Qualifications 

Voting membership on decision-making body was not unreasonably restricted on basis of technical 

qualifications or other such requirements. 

B ANSI E

Requi

4 Progress/Updates 

are Communicated 

Timely and adequate notice of standards activity was announced in suitable media as appropriate to demonstrate the opportunity for participation by all directly and materially affected persons. 

B ANSI E

Requi

5 Transparent The process was transparent through significant stages of the standard's development and operation.2 B ISO 146 Consideration of All 

Viewpoints 

The standards development process included fair and equitable consideration of all viewpoints. B ANSI E

Requi

7 Diversity of 

Interests 

Participation from diverse interest categories was actively sought with the objective of achieving balance so that no single interest category constitutes a majority of the membership of the decision-making body.3

B ANSI E

Requi

8 No Funding 

Conflicts 

Funding sources for standards development did not create conflicts of interest. B ISO 14

9 Consensus Effort Reasonable efforts were made to achieve consensus throughout the process; prompt consideration was 

given to all views, and evidence of consensus4 reached was documented. 

B ISO 14

10 Effort to Resolve 

Objections 

An effort to resolve all objections was made in a fair and unbiased way. Commenters were informed of the 

resolution of their comments and advised of their right to appeal. 

B ANSI E

Requi

11 Appeals Mechanism Written procedures contain an appeals mechanism for the prompt and impartial handling of procedural 

complaints regarding any action or inaction of the decision-making body. 

B ANSI E

Requi

12 Appeals Open Appeals procedures provide for participation by all parties concerned without imposing an undue financial 

or administrative burden on them. 

B ANSI E

Requi

13 Good-faith on 

Conflicts 

A standards developing organization shall make a good-faith effort to resolve potential conflicts with the 

requirements of other existing standards and to coordinate standardization activities.5

B ANSI E

Requi

14 Standards Updated Standards are revised or reaffirmed every five years at minimum. B ANSI E

Requi

Section II: Guidelines for the Environmental Effectiveness of the Standards[Revised per public comments – see www.epa.gov/epp/draftguidelines/RevGuidelinesSII.pdf] 

1 Functional 

Performance 

Final product standards require that the product’s functional performance is consistent with comparable conventional products or standard industry test methods. 

B FAR 2

acquis
DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & ECOLABE

# Guideline Name Guideline B/L Sour

requirthe co

2 Align with Relevant 

Standards 

To avoid duplication or confusion in the marketplace, standards for green products align with relevantexisting standards, including building upon existing, federal, regional, national, and international standards where relevant to the scope and goals of the standard. 

B 

3 Measurability The product environmental performance criteria are measurable. B ISO 144 Credible Scientific 

Reasoning 

The criteria reflect a credible scientific reasoning process and reference, incorporate or are based on the best available science. 

B ISO 14

5 Performance-Based The criteria are performance-based when such criteria may reasonably be used in lieu of prescriptive 

criteria. 

L OMB 

6 Lifecycle Stages The standard’s developer considered the full range of product life cycle stages. Exclusion of a significant 

lifecycle stage is explained in the standard or other appropriate, publicly available documentation. 6

L ISO 14

7 Multiple 

Environmental Attributes 

Standards developers considered the full range of environmental attributes. Exclusion of a significantenvironmental attribute is explained in the standard or other appropriate, publicly available documentation.

7

L 

8 Weighting 

Methodologies 

If a standard uses methodologies to weight and aggregate multiple attributes into a single score, those methodologies are well-documented in the standard. 

B 

9 Hotspots Where there are certain lifecycle stages or attributes that dominate the opportunity for environmental

improvement, those significant attributes (or "hotspots") are clearly defined and given greater emphasis in differentiating environmental performance. If additional attributes are addressed, the standard clearly identifies any known trade-offs between attributes.

8

B 

10 Significant 

Measurable Difference 

Product environmental criteria differentiate products from others in the product category, based on a significant measurable difference in environmental impact for the environmental attribute(s) for which the product makes a claim. 

B ISO 14

11 Intrinsic Hazards Product environmental criteria focus on the intrinsic hazards of chemicals, and require safer substitutes to 

the extent possible, considering existing data and availability of functional alternatives.

9

L 

12 Ingredient 

Disclosure 

The standard encourages manufacturers to disclose ingredients in products (to other businesses in the supply chain and/or consumers).10

L 

13 Impact Assessment 

Disclosure 

The standard encourages manufacturers to disclose the results of life cycle assessments and other product environmental or human health assessments that have been conducted.11

L 

Section III: Guidelines for Conformity Assessment12

1 Follow Relevant 

Standards 

Conformity assessment bodies follow relevant International Standards, and other normative documents. B ISO/IE

2 Independence The decision-making process of bodies involved in conformity assessment (including those evaluating, 

inspecting and testing conformity to standards) are independent from those organizations to whom they are providing their services. 

B ISO/IE

3 Slide Fee Scale Conformity assessment bodies offer a sliding scale of certification fees in order to be accessible to small 

businesses. 

L 

4 Accreditation Conformity assessment bodies are accredited as being in compliance with relevant International Standards, 

and other normative documents. 

L ISO/IE

OR apply the evaluation factors below, which are consistent with the requirements of internationally accepted standards for operations of a conformity assessment body. 

_ 
DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & ECOLABE

# Guideline Name Guideline B/L Sour

4.1 Objective & 

Impartial Structure 

Conformity assessment bodies are structured in such a way that they are able to provide an objective and 

impartial evaluation of conformity. Decisions are based on the objective evidence of conformity (or nonconformity) obtained by the body. 

B ISO/IE

4.2 Free from Undue 

Pressures 

Conformity assessment bodies ensure that management and personnel are free from any undue 

commercial, financial and other pressures that could compromise the confidentiality, objectivity or 

impartiality of its process and decisions. 

B ISO/IE

4.3 Documented 

Procedures 

The conformity assessment process followed has documented procedures B ISO/IE

4.4 Take All Necessary 

Steps to Evaluate Conformance 

Conformity assessment bodies take all steps necessary to evaluate conformance with the relevant product 

standard requirements. 

B ISO/IE

4.5 Role Separation Each decision on conformity is taken by a person(s) different from those who carried out the evaluation of 

conformity. 

L ISO/IE

4.6 Certification 

Conditions Specified 

The conditions for granting, maintaining and extending certification and the conditions under which certification may be suspended or withdrawn, partially or in total are specified in the conformity assessment process. 

B ISO/IE

4.7 Records 

Management 

Conformity assessment bodies establish and maintain procedures to control all documents and data that 

relate to its functions. Records are identified, managed and disposed of in such a way as to protect the confidentiality of conformity assessment related information. 

B ISO/IE

4.8 Dispute Resolution 

Procedures 

Conformity assessment bodies have documented policies and procedures for the resolution of complaints,

appeals and disputes. 

B ISO/IE

4.9 Chain-of-Custody 

Procedures 

The conformity assessment bodies have effective traceability or chain-of-custody procedures where this is 

necessary to ensure qualified products meet the standard 

L 

4.10 Periodic Evaluation 

of Marked Products 

Where a conformity assessment body authorizes the continuing use of its mark on products of a type which 

have been approved to carry the mark it periodically evaluates the marked products to confirm that they continue to conform to the standards. 

L ISO/IE

4.11 Content of 

Declarations of Conformity 

Declarations of conformity contain at least information on the identity of the issuer of the declaration, the 

object of the declaration, the standards or other specified requirements with which conformity is declared, 

and the person signing for and on behalf of the issuer of the declaration of conformity. 

B ISO/IE

4.12 Suitable Action for 

Misuse 

Incorrect, misleading, or unauthorized use of licenses, certificates, or conformity marks is dealt with by suitable action (from the mark owner). 

B ISO/IE

17030 

4.13 Quality Objectives Conformity assessment bodies define and document commitment to fulfilling quality objectives. B ISO/IE4.14 Sufficient Personnel Conformity assessment bodies employ a sufficient number of personnel having the necessary education, 

training, technical knowledge and experience for performing conformity assessment functions. 

B ISO/IE

4.15 Adequate Facilities 

& Equipment 

Conformity assessment bodies have available suitable and adequate facilities and equipment to permit all required activities to be carried out. 

B ISO/IE

4.16 Transparent Process Certification bodies provide public access to or disclosure of, appropriate and timely information about the 

certification processes; including its rules and procedures for granting, maintaining, extending, suspending 

and withdrawing certification. 

B ISO/IE

4.17 Information on Fees General information on the fees charged to applicants is provided. B ISO/IE4.18 Information on 

Financial Support 

Public access to, or disclosure of, a description of the means by which the conformity assessment body

obtains financial support is provided. 

L 

4.19 Information on 

Scoring 

Conformity assessment bodies make publicly available the scoring, credits and levels achieved by products which conform to the standard. 

L 
DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & ECOLABE

# Guideline Name Guideline B/L Sour

Section IV: Guidelines for the Management of Ecolabeling Programs

13

1 Document 

Commitment to Quality 

Programs define and document their policy, objectives for, and commitment to quality. B ISO/IE

2 Evaluate 

Effectiveness 

The program evaluates the effectiveness of the standard in reducing environmental impacts. L 

3 Dispute Resolution 

Process 

The program has a documented policy and procedure for the resolution of complaints, appeals and disputes. 

B ISO/IE

4 Disclose 

Stakeholders 

Stakeholders who are involved in the ongoing governance and/or operations of the program are disclosed. L 

5 Balance of Interests Formal rules and procedures provide for a balance of interests among stakeholders in program governance. L 6 Free from Undue 

Pressures 

Programs ensure that management and personnel are free from any undue commercial, financial and other pressures that could compromise the confidentiality, objectivity or impartiality of their operations and decisions. 

B ISO/IE

7 Limit Administrative 

Requirements 

Administrative ecolabel program requirements are limited to those necessary to establish conformance and operate the program. 

L ISO 14

8 Information on 

Financial Support 

Public access to, or disclosure of, a description of the means by which the conformity assessment body

obtains financial support. 

L ISO 14

9 Information on Fees General information on the fees charged to applicants is provided. B ISO/IE

14024 

10 Publicly Available 

Criteria 

The ecolabel's criteria and/or standard are publicly available.14 B ISO/IE

11 Grant the Use of 

the Mark 

The ecolabel program grants the use of the label, mark or declaration when the applicant and its products 

meet the administrative and technical requirements for the program. 

B ISO 14

12 Suitable Action for 

Misuse 

Incorrect, misleading, or unauthorized use of licenses, certificates, or conformity marks is dealt with by 

suitable action (from the mark owner). 

B ISO 14

13 Mutual Recognition Mutual recognition among ecolabels and standards is encouraged, and may include the mutual recognition 

of tests, inspections, conformity assessment, and administrative procedures and, where appropriate, product environmental criteria. 

L ISO 14

14 Publicly Available 

Directory 

The program provides a publicly available directory of labeled products and their suppliers. B ISO/IE

15 Current Directory The directory of labeled products and their suppliers is kept current. B ISO/IE16 Searchable 

Directory 

Information in the directory of labeled products and their suppliers is provided in searchable format. L 

17 Regional 

Information 

The program provides information on labeled products availability in regional markets. L ISO 14

18 Analyses of Market 

Uptake 

The program conducts periodic analyses of the uptake of the ecolabel in the marketplace and discloses the 

results. 

L 
Notes: 

1. IAF International Accreditation Forum: http://www.iaf.nu; IFAN International Federation of Standards Users: http://www.ifan.org; ISO: 

http://www.isealalliance.org/code

2. Transparency implies that information was available to interested parties for inspection and comment where appropriate; and includes 

selection and development of product environmental criteria; and product function characteristics. 

3. While this baseline represents an acceptable level of balance, additional steps have been taken by a number of standards development 

balance of diverse interests (e.g., limiting number of votes per organization, confirming accuracy of affiliations, actively recruiting additstakeholder categories). Such proactive approaches could be recognized as leadership. 

4. According to the Office of Management and Budget (OMB) Circular A-119, consensus “is defined as general agreement, but not necessa

process for attempting to resolve objections by interested parties, as long as all comments have been fairly considered, each objector i

her objection(s) and the reasons why, and the consensus body members are given an opportunity to change their votes after reviewing http://www.whitehouse.gov/omb/circulars_a119#4 Consensus is implemented by standards development organizations in many differ

75 percent approval of an action while others might require 66 percent or 50 percent for the same action to be approved. 

5. A conflict exists when the terms of a standard are inconsistent or incompatible with the terms of the other standard to the extent that 

would preclude proper implementation of the other. 

6. Life cycle stages of a product include sourcing of raw materials, to manufacturing, packaging, transportation, distribution, retailing, use 

the product when it is no longer needed (through reuse, repair, upgrading, recycling, or safe disposal). The Federal government recognassessments (LCA) is challenging at this time due to cost, access to data, and uncertainties associated with the methodologies and toolsencourage standards developer to use life cycle thinking as they develop criteria for products. 

7. When a standard does not address a significant or major environmental attribute (aka “hotspot”), standards developers are encourage

is to ensure clarity about the relevance of environmental attributes that may be included (or excluded) from the standard. Environmenlimited to, human and environmental toxicity, environmental fate, air pollution, climate change, stratospheric ozone depletion, natural quality. 

8. Depending on the product and application, it may be appropriate to develop standards that address those significant attributes, and do 

attributes or life cycle stages. However, if reliable evidence is available to meaningfully differentiate the performance of that product battributes of concern or lifecycle stages (e.g., packaging, energy use in manufacturing, etc.), standards for green products should considwell. Claims about products meeting environmental standards should be consistent with the standard's scope and avoid broad claims oother factors were not considered when the standard was developed (e.g. WaterSense is clearly about water, ENERGY STAR about ene

9. A hazard-based approach, grounded in Green Chemistry principles, can reduce the use of hazardous substances, and lower overall risk 

to this focus is an understanding of the potential hazards of chemicals in products and availability of safer alternatives. 

10. The intent of this guideline is to encourage greater disclosure, while recognizing a number of challenges in doing so for manufacturers, 

and intellectual property confidentiality. 

11. Sound human health and environmental decisions regarding the manufacture, purchase, use, and disposal of products depend on relia

health and environmental impact of those products. The intent of this guideline is to encourage the appropriate and voluntary sharing available, so that others may learn and benefit. 

12. If a standard does not have an associated second- or third-party conformity assessment program, or it is determined that a supplier’s d

product standard, then this category of Guidelines would not be applicable. 

13. The Management of Ecolabeling Programs Guidelines would not apply to product environmental standards that are not associated with 14. Publicly available means generally available to all without restriction (other than a fee for purchasing the standard or similar such requi