Revised Guidelines on the Environmental Effectiveness of the Standards (Section II)

EPA revised Section II of the Guidelines (“Environmental Effectiveness”), in response to public comments. As noted in the Responnot intend to revise the other Guidelines at this time, pending the finalization of OMB’s revision of the Circular A‐119 and learnin

It is important to note that language in this section has been changed to mandatory language (e.g., “The standard requires....”) t

Leadership Guidelines. However, the applicability of Leadership Guidelines, and the precise methods of conformance, will vary b

establish conformance with Section II of the Guidelines, a standard’s or ecolabel’s specific criteria will be evaluated as a group, rait is not necessary for every criterion in a standard or ecolabel to satisfy every Guideline, so long as the standard or ecolabel as a 

requisite Guidelines. For example, not all criteria need to demonstrate measurability and a significant measurable difference per there are criteria that satisfy this Guideline for all of the product’s key environmental impacts. Similarly, a single criterion may be 

ecolabel to satisfy Guideline II.10 (Ingredient Disclosure); in this case, the other criteria would not need to address this issue.

Also, functional performance issues are generally best addressed by the purchasing agency’s established processes for setting an

requirements. If it is likely that a functional performance issue may not be adequately addressed through purchasing agency properformance should also be considered when utilizing standards and ecolabels so that the functional performance of conforming 

conventional products or standard industry test methods.

Revised DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & E

# Guideline Name Guideline B/L* Prim

Refe

1 Align with

RelevantStandards

To avoid duplication or confusion in the marketplace, environmental performance

standards shall align at both thematic and performance levels with relevant existing

standards, including building upon federal, regional, national, and international

standards where relevant to the scope and goals of the standard.

Performance alignment refers to performance equivalent to or better than relevant

existing standards.

B 

2 Measurability and

SignificantMeasurableDifference

The product environmental performance criteria are measurable and convey improved

environmental outcomes for the environmental impact(s) addressed. Criteria should

ensure that environmental performance of certified products exceeds legal minimum

requirements (where applicable), and exceeds the industry average for the

environmental attribute(s) for which the product makes a claim. Quantitative measures

are strongly preferred, but qualitative measures may be used where quantitativeapproaches are infeasible.

B ISO 
Revised DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & E

# Guideline Name Guideline B/L* Prim

Refe

3 Data Quality and

Reliability

The criteria reflect a credible scientific reasoning process and reference and incorporate

or are based on the best available science and supporting studies. The criteria should be

scientifically and technically valid, based upon accurate, reliable, and unbiased

information.

B ISO 

1404InfoQua

Guid

4 Performance‐

Based

The criteria are performance‐based when such criteria may reasonably be used in lieu of

prescriptive criteria. Prescriptive criteria are used when there is science‐based evidence

to support that the action will achieve the desired outcome. Criteria must be sufficiently

specific with respect to a desired performance outcome or prescriptive outcome.1

L OM

5 Hotspots Where there are certain lifecycle stages or impacts that dominate the overall

environmental and/or health impact of the product category, those significant impacts

(or "hotspots") are clearly defined and given greater emphasis in differentiating

environmental performance. If additional impacts are addressed, the standard clearly

identifies any known trade‐offs between impacts.2

B 

6 Multiple

Environmental

Impacts

Standards developers considered the full range of environmental and human health

impacts applicable to the relevant product or product sector. Exclusion of a significant

impact is explained in the standard or other appropriate, publicly available

documentation. The explanation includes scientific reasoning of the exclusions and

addresses the measurability of the impact, and/or reasoning pertaining to the standard

to the standard development organization’s targeted focus on a particular

environmental medium (or media).3

L ISO 

7 Lifecycle Stages Standards developers considered all product lifecycle stages. Exclusion of a lifecycle

stage with clear impacts is explained in the standard or other appropriate, publicly

available documentation.4 This guideline is not applicable to process and production

method (PPM) standards, or other standards that do not address the environmental

performance of a finished product.

L ISO 

8 Weighting

Methodologies

If a standard uses methodologies to weight and aggregate multiple attributes into asingle score, the weightings are explicitly defined, and methodologies are well‐

documented in the standard and justified on a scientific basis where possible.

B 

9 Intrinsic Hazards Product environmental criteria focus on the intrinsic hazards of chemicals across the full

lifecycle of the product, and require safer substitutes where possible, considering

existing data and availability of functional alternatives (including non‐chemical,

alternative design‐based approaches, as applicable).5

L Prin

Gree
Revised DRAFT GUIDELINES FOR PRODUCT ENVIRONMENTAL PERFORMANCE STANDARDS & E

# Guideline Name Guideline B/L* Prim

Refe

10 Ingredient

Disclosure

The standard requires manufacturers to disclose ingredients in products (to other

businesses in the supply chain and/or consumers).6 The method of disclosure may vary

depending on product category. This guideline is not applicable to process and

production method (PPM) standards, or other standards that do not address the

environmental performance of a finished product.

L Prin

Gree

11 Impact

AssessmentDisclosure

The standard requires manufacturers to disclose the results of lifecycle assessments and

other product or process environmental or human health assessments that have been

conducted. All relevant environmental and human health impact categories are

included in this disclosure. Established and well‐recognized methodologies areencouraged, such as ISO guidelines for conducting LCAs.7

L 

*B = Baseline; L = Leadership.

**Where a primary reference is not noted, EPA developed the guideline based on EPA stakeholder listening sessions and/or EPA 

Notes:

1. OMB A‐119 defines "performance standard" as a standard that states requirements in terms of required results with criteria 

but without stating the methods for achieving required results. A performance standard differs from a prescriptive standard, 

design requirements, for example materials to be used, how a requirement is to be achieved, or how an item is to be fabricat

Unacceptably vague criteria would include those stating that an entity should “be involved in” or “promote” an activity, appr

without specifying resulting performance or prescriptive outcomes.

2. Depending on the product and application, it may be appropriate to develop standards that address those significant impacts

less relevant, impacts or lifecycle stages. See definition of lifecycle stages in footnote 4. However, if reliable evidence is availa

differentiate the performance of that product based on additional environmental impacts of concern or lifecycle stages (e.g., 

manufacturing, etc.), standards for green products should consider addressing those impacts, as well. Hotspots can be ident

lifecycle assessment, or by consulting existing, credible literature and analyses of significant impacts available at the product 

about products meeting environmental standards should be consistent with the standard's scope and avoid broad claims of e

if other factors were not considered when the standard was developed (e.g. WaterSense is clearly about water, ENERGY STAR 

3. When a standard does not address a significant or major environmental impact (aka “hotspot”), standards developers are enc

exclusion. The intent isto ensure clarity about the relevance of environmental impacts that may be included (or excluded) fro

Environmental impactsinclude, but are not limited to, human and environmental toxicity, acidification, smog, climate change

depletion, natural resource depletion, and water quality. For simplification, environmental impacts also include environment

use, water use, material use and waste generation.

4. Lifecycle stages of a product include sourcing and processing of raw materials to manufacturing, packaging, transportation, dist

product, and end‐of‐life management (through reuse, repair, upgrading, recycling, or safe disposal). The Federal government r
assessment is a complex and evolving field and performing full lifecycle assessments (LCA) is challenging at thistime due to cost, 

uncertainties associated with the methodologies and tools. Also, the Federal government recognizes that there are environme

cannot adequately address impacts such as biodiversity loss, land use changes, impacts to ecosystem services, and biogenic carbo

guideline intendsto encourage standards developers to use lifecycle thinking asthey develop criteria for products.

5. An intrinsic hazard is the potential for harm based on the chemical structure and properties that define its ability to interact w

hazard‐based approach, grounded in Green Chemistry principles, can reduce the use of hazardoussubstances, and lower over

environment. Key to this approach is an understanding of the potential hazards of chemicalsin products and availability of saf

speaking, “hazardous chemicals” are those which have a human or environmental toxicity profile such that exposure to peop

environment could lead to adverse health impacts. Consistent with Green Chemistry principles and established methods for r

management, standards and ecolabel programs can help lower overall risk to people and flora/fauna present in the environm

to understand how the reduction of human and ecological health hazards can contribute to overall risk reduction. Steps can t

the hazards of product ingredients through: ingredient substitution; alternative design approaches; and/or reducing relevant 

products or flora/fauna present in the environment. Standards and ecolabel programs should also assess the potential trade‐

alternatives/substitutes elsewhere in a product's lifecycle and impacts on the functional ("fitness for use") performance of th

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

chain complexity and intellectual property confidentiality. This guideline is not relevant to products that do not include chem

hazards.

7. Sound human health and environmental decisionsregarding the manufacture, purchase, use, and end‐of‐life management of 

and accessible data on the human health and environmental impact of those products. The intent of this guideline is to encou

voluntary sharing of thisinformation, when it is available, so that others may learn and benefit.