Code of Good Practice for claims

relative to product-related life cycle

greenhouse gas (GHG) emissions
Draft 1-0

Document Title

The document was previously titled "Product-related Emissions Communications

Guidance (PECG)". The new title responds to suggestions made by the Reduction and
Communication Steering Group, but is currently provisional pending further comment.

May 2008

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 BACKGROUND AND CONTEXT

The Carbon Trust and product related greenhouse gas emissions assessment

The Carbon Trust is an independent company set up by the UK Government in 2001 in

response to the threat of climate change. Its mission is to accelerate the move to a low
carbon economy by working with business and the public sector to reduce carbon
emissions and develop commercial low carbon technologies.

Accelerating the move to a low carbon economy in order to mitigate climate change will
require fundamental changes to the way that businesses deliver goods and services. In
2005, in order to help businesses deliver this change, the Carbon Trust began working
with companies to develop a method to measure and identify opportunities to reduce
carbon emissions across the supply chain. In short, this required working towards the
creation of a consistent and standard measurement method.

In March 2007, following research and consultation into this area with business and other
stakeholders, the Carbon Trust launched a voluntary initiative to measure, reduce and
communicate the life cycle greenhouse gas (GHG) emissions of products1. The initiative
aims to encourage companies to reduce emissions across their supply chains by
providing robust, transparent and consistent information regarding their products’ life cycle
GHG emissions. Such information can then be used by businesses and other
stakeholders to make informed purchasing and business decisions.

The information being developed to support businesses seeking to reduce their product
GHG emissions includes the development of three core documents:

- A single standard method for the assessment of the life cycle greenhouse gas
emissions of goods and services (PAS 2050). This document defines how life cycle
GHG emissions of a product should be measured.

- The Product-related Emissions Reduction Framework (PERF). This document sets out
the requirements for making credible claims regarding reduction of life cycle GHG
emissions of products, as measured using PAS 2050.

- Code of Good Practice for claims relative to product-related life cycle greenhouse gas
(GHG) emissions (Code of Good Practice for claims) document. This document
supports companies implementing the PAS 2050 and/or PERF by setting out the
requirements for consistent communication of product-related life cycle greenhouse
gas emissions and emission reductions

The PAS 2050

The PAS 2050 is a stand-alone open specification being developed in partnership

between the Carbon Trust, the UK government Department for Environment, Food and
Rural Affairs (Defra) and the British Standards Institution (BSI) British Standards. The
specification sets out a method to assess the life cycle GHG emissions of products. The
reduction framework (PERF) and Code of Good Practice build on the PAS 2050, but are
separate from it.

1
For the purpose of this document products include goods and services.
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PAS 2050 benefits organisations, businesses and other stakeholders by providing clarity
and consistency for quantifying the life cycle GHG emissions associated with goods and
services. Specifically, PAS 2050 provides the following benefits:
(a) For organisations that supply goods and services:
• allows internal assessment of the existing life cycle of goods and services;
• facilitates the evaluation of alternative product configurations; sourcing and
manufacturing methods; raw material choices and supplier selection on the basis of
the life cycle GHG emissions associated with goods and services;
• provides a benchmark for ongoing programmes aimed at reducing GHG emissions;
and
• allows for a comparison of goods or services using a common, recognised and
standardised approach to life cycle emissions assessment
(b) For customers of goods and services:
• provides a common basis from which the results of life cycle GHG emissions
assessments can be reported and communicated; and
• provides an opportunity for greater customer understanding of life cycle GHG
emissions when making purchasing decisions and using goods and services.

The PERF and the Code of Good Practice for claims relative to product-related life
cycle greenhouse gas (GHG) emissions

Companies who have assessed their product-related life cycle GHG emissions and are
working to reduce them may want to make public claims about their reduction
achievements. Today, no guidance exists to support companies making credible product-
related emissions reduction claims. The PERF is being developed to address this gap.
Specifically, the aim of the PERF is to encourage continual reduction in product-related
GHG emissions by setting out requirements for demonstrating and making claims relating
such reduction.

While PAS 2050 provides a common basis for the comparison and communication of
results arising from the use of the specification, it does not provide any requirements
relating to communication of the result. For those companies wishing to communicate
information relating to their life cycle GHG emissions based on their PAS 2050 result on a
clear, consistent and comparable basis, appropriate guidance will be set out in the Code
of Good Practice for claims relative to product-related life cycle greenhouse gas (GHG)
emissions (this document).

Claims can be made in a variety of ways (e.g. literature, advertisements, labels) and it is
important that, whatever the medium used, any claims are robust, credible and consistent
so that they can contribute positively to influencing business and consumers purchasing
behaviours and other decisions, and do not cause confusion or mis-information.

Sufficient comparable information does not currently exist to allow comparisons of

product-related emissions to be made (e.g. for example to state that a product is a ‘low
carbon product’ based on comparison with other brands). Similarly, it is not currently
possible to set relative reduction performance targets. The PAS 2050, the PERF and the
Code of Good Practice for claims are being designed so that they will lead to the
development of consistent information on product-related life cycle emissions and their
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reductions, which, over time, could lead to the generation of sufficient data to compare the
life cycle GHG emissions of a range of products and services.

The three documents (PAS 2050, PERF and Code of Good Practice) are being developed
with a view to being internationally applicable. They are being developed through
consultative processes involving international stakeholders, specialist international
working groups and pilots with companies in the UK and abroad. In addition, the Carbon
Trust is engaging with international standard setters and relevant national initiatives in
other countries to ensure alignment and collaboration in this area.

Development Process

The second draft of PAS 2050 was released for consultation on February 18th 2008. For
more information about the PAS 2050 and the development process, please see www.bsi-
global.com/PAS2050.

The Product-related Emissions Reduction Framework (PERF) is being developed by

Carbon Trust with the help of Arup, OneWorldStandards and the Pacific Institute with
technical support from E4tech. It builds on PAS 2050 but is separate from it. The first draft
was released for public consultation on March 3rd 2008. After analysis of the comments
and discussion with the Reduction and Communication Steering Group this second draft
is being released for public consultation in May 2008.

The Code of Good Practice is being developed by the Carbon Trust and the Energy
Savings Trust, with support from Arup, OneWorldStandards and E4tech. This document
also builds on PAS 2050 but is separate from it. After review by a group of communication
experts the draft Code of Good Practice is being released for public consultation in May
2008 along with the second draft of the PERF.

These initiatives are being overseen by two independent steering groups: one covering
PAS 2050 and another covering the PERF and Code of Good Practice. Both steering
groups include members from a wide range of stakeholder organisations representing
academia, non-governmental organisations, business government, the Energy Savings
Trust and the Carbon Trust. The members of the Reduction and Communication Steering
Group are listed in Appendix 1.

The development process will comply with the ISEAL Code of Good Practice for Setting
Social and Environmental Standards (‘the ISEAL Code’)2 to ensure that the framework is
internationally applicable. In particular, the Carbon Trust is committed to:

• ensuring that there is broad participation in development of this document by the

full range of interested parties;

• being transparent in relation to governance, procedures, participation, comments

resolution and decision-making; and

2
The International Social and Environmental Accreditation and Labelling (ISEAL) Alliance is an association of
leading voluntary international standard-setting and conformity assessment organisations that focus on social
and environmental issues. Members include the Forestry Stewardship Council, Fairtrade Labelling
Organisation and Social Accountability International, amongst others. The ISEAL Code of Good Practice is the
international reference for setting credible voluntary social and environmental standards. It is referenced by a
range of governmental and inter-governmental guidelines as the measure of credibility for voluntary social and
environmental standards. See www.isealalliance.org for more information
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 • striving for consensus on the document's final content among a balance of the
interested parties.

The final document will be freely and publicly available.

Further information, including a copy of the governance and procedures under which this
framework is being developed, is available at
http://www.carbontrust.co.uk/carbon/briefing/perf.htm.

Applicability

The outcome of this initiative will be a voluntary framework to assist companies that wish
to communicate the lifecycle GHG emissions of their products and their reduction. The
framework will be applicable to companies in any stage of a supply chain and will be
internationally available.

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Notes since previous draft

The following drafting convention has been used for this draft:

Grey boxes are used to highlight the changes that have been made to each section
since the PECG 'working draft 0-6' (product-related emissions communications
guidance, now Code of Good Practice for claims relative to product lifecycle GHG
emissions) and to explain the reasoning behind the changes.

Drafting notes and options are outlined in the clear boxes

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 Code of Good Practice for product-related life cycle greenhouse gas (GHG)
emissions claims DRAFT 0-9

Contents

i. Introduction
ii. Objectives
iii. Scope
iv. References
v. Definitions

1. Declarations of compliance
2. Principles for claims about product lifecycle GHG emissions
3. Communicating quantitative information about product-related life cycle
GHG emissions
4. Communicating reduction claims on product lifecycle GHG emissions
5 Reporting supplementary information about product-related life cycle GHG
emissions: the Product Emissions Report

i. Introduction

NOTES

This introductory section has been expanded to provide a better explanation to the
general approach to communicating lifecycle GHG emissions of products and their
reduction, taken in this Code of Good Practice, and the rationale behind it.

This Code of Good Practice for Claims enables companies to communicate the life cycle
GHG emissions and/or emission reductions associated with their products on a clear and
consistent basis.

This Code is based on the technical requirements for assessing GHG emissions specified
in BSI PAS 2050:2008 - Specification for the assessment of the life cycle greenhouse gas
emissions of goods and services, and the Carbon Trust Product-related Emissions
Reduction Framework (PERF).

Companies are encouraged to use this Code to present information about the lifecycle
GHG of their products and the reductions of those emissions to customers, suppliers,
investors and the general public.

NOTE Compliance with this Code does not, of itself, give companies any rights to use the Carbon
Trust nor the Energy Saving Trust name or logo to communicate their product-related GHG
emissions in any context whatsoever.

Challenges and general approaches

This Code recognises and tries to address a number of challenges associated with claims
about greenhouse gas emissions and/or reductions in emissions of products.

The conflict between rewarding improvement and rewarding absolute performance

There is an inherent conflict between claims that focus only on improvement and claims
that focus only on absolute levels of performance. In the case of product-related GHG

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emissions a company could claim that it has reduced the lifecycle GHG emissions of a
product, or it could claim that the product has low lifecycle GHG emissions. There are
challenges associated with each type of claim.

The challenge of 'reduction' claims is that they do not tell a consumer anything about the
absolute level of emissions. A product claiming major reductions in its life-cycle emissions
may still have higher emissions than a similar product whose life-cycle emissions were
low to begin with. The challenge of 'low emissions' claims is that currently there is no
sufficiently consistent information available to define what is meant by 'low' in a robust
way.

This Code addresses this challenge by requesting that if a company makes claims about
the reduction in emissions associated with a product, it shall also declare information
about the absolute levels of emissions associated with the product. The intent of this
approach is that it rewards companies for taking immediate action to reduce the GHG
emissions associated with their products, whilst simultaneously making information
available which, in the longer term, will allow consumers to distinguish between 'low' and
'high' GHG emissions products.

The challenge of comparability

Currently there is no sufficient information to make comparisons of product carbon
performance within or across categories.

The PAS 2050 aims to establish a comprehensive and replicable method for evaluating
product-related GHG emissions. Comparability of information depends both on having
consistent measurement method (PAS2050), and communication guidance (Code of
Good Practice). This Code focuses on providing guidance to allow companies to
communicate consistently GHG emissions and their reduction for products assessed
according to the PAS 2050. The Code requires companies to report publicly absolute
emission levels of the product(s), and to provide supporting information explaining how
these emissions were measured in a consistent and comprehensible format.

This approach aims to support the development, over time, of clear, consistent, readily
accessible data which will in the future enable comparison of products’ emissions within
and across categories.

The conflict between simplicity and completeness

The evaluation of product-related GHG emissions is complex. Decisions have to be made
about the scope of the calculation (for example whether the calculation should include
emissions associated with embodied carbon, i.e. emissions up to the point of sale or also
emissions accrued during the “use phase”); and about how to present these results. The
situation is further complicated by schemes to 'offset' emissions to make a process
'carbon neutral'. Some effort is required to encourage consumer acceptance in relation to
claims about GHG emissions.

Any company wanting to communicate messages about "product-related GHG emissions

reductions" has to contend with this high level of complexity, and the consequent need for
customer understanding.

Increasing the amount of information associated with a claim may increase the level of
confusion, and fail to attract customers. However, failing to acknowledge the inherent
complexity may lead to the perception that a company is making incomplete or even
misleading claims.

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The approach taken in this Code is to recognise that on-product or 'point of sale' material
will often inevitably be simplified, in order to be attractive to customers. However, this
simplicity must be backed up with a high level of transparency through the provision of
detailed information, in order to avoid the perception that there is any intent to mislead
customers.

This Code of Good Practice adopts a 'principle' based approach to address these
challenges. The objectives, scope, reference and definitions are first specified. The Code
then lays out general guidance relating to claims in four sections:

The first section describes the approach taken to verification. Section two introduces
general and specific principles in relation to claims about greenhouse gas emissions and
emission reductions. Section three provides specifications for reporting quantitative
information about product-related life cycle GHG emissions. Section four provides
specification about communicating reduction claims, Finally, section five specifies
requirements for the provision of supplementary information in the form of a Product
Emissions Report for each product about which a claim is made.

ii. Objectives
The overall objective of this Code is to provide the basis to allow consistent information of
product related GHG emissions or their reductions, measured in conformity with the
PAS2050 and the PERF, on which consumers, companies and other stakeholders can
make purchasing and business decisions.

This Code provides:

• consumers, companies and other stakeholders with clear, credible, supporting

information to communicate lifecycle GHG emissions of products on a consistent
and comparable basis; and
• back up claims relating to reductions in life cycle GHG emissions associated with a
specified product over time.

iii. Scope
This Code of Good Practice may be used by any company that needs a clear, credible
structure and format for reporting to internal or external stakeholders on the life cycle
GHG emissions associated with its products, or the reduction of such emissions.

iv. References
The following references are all informative rather than normative

BS EN ISO 14044:2006, Environmental management — Life cycle assessment —

Requirements and guidelines

BS ISO 14064-1:2006, Greenhouse gases - Part 1: Specification with guidance at the

organization level for quantification and reporting of greenhouse gas emissions and
removals

BS ISO 14065:2007 Greenhouse gases. Requirements for greenhouse gas validation and
verification bodies for use in accreditation or other forms of recognition

PAS 2050: 2008 Specification for the assessment of the life cycle greenhouse gas
emissions of goods and services (DRAFT)

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ISO 14025:2006 Environmental labels and declarations -- Type III environmental
declarations -- Principles and procedures

v. Definitions
NOTE: definitions marked with an asterisk are taken from the draft BSI PAS 2050 and will need to
be modified in accordance with subsequent changes in the drafting of the PAS.

*carbon dioxide equivalent (CO2e)

unit for comparing the radiative forcing of a greenhouse gas measure of the amount of
global warming arising from different greenhouse gasses, expressed in terms of the
amount of carbon dioxide that would have an equivalent global warming potential

claim
information appearing on a product, its packaging, or in related literature or advertising
material, relating to its environmental aspects. It can take the form of text, symbols, or
graphics.

NOTE A straight piece of advice to consumers of the product – for example, about care in its use
or disposal – is not regarded as a claim. But such advice should still give consumers relevant
information on which they can realistically act.

(from UK Department of Trade and Industry Green Claims Code, June 2000)

*functional unit
quantified performance of a product for use as a reference unit (after BS EN ISO
14044:2006)

*greenhouse gases (GHGs)

gaseous constituents of the atmosphere, both natural and anthropogenic, that absorb and
emit radiation at specific wavelengths within the spectrum of infrared radiation emitted by
the Earth's surface, the atmosphere, and clouds.

*life cycle
consecutive and interlinked stages of a product system, from raw material acquisition or
generation of natural resources to final disposal (BS EN ISO 14040:2006)

*life cycle GHG emissions

sum of all GHG emissions occurring at each stage of the product life cycle and within the
specified system boundaries of the product

*product(s)
goods or services resulting from a supply chain

*product category
group of products that can fulfil equivalent functions (ISO 14025:2006)

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1 Declarations of compliance

NOTES ON SECTION 1

This section was previously numbered as section 4. It establishes the framework for
verification, and puts this in the context of the principle of verifiability established by
ISO14020. There are two key elements: a) that companies cannot claim compliance with
this Code unless this claim(s) have been verified by an accredited body; b) that all the
quantitative data they quote has been verified by a PAS2050 qualified verification body.

1.1 Declarations of conformity with this Code should only be made by companies
whose compliance has been verified by an independent third party organisation that is
able to demonstrate its compliance with ISO 14065 and which has certification to PAS
2050 within its scope.

1.2 Quantitative claims of the life cycle GHG emissions of goods and services
(including baseline figures and reductions in emissions over time) should only be made on
the basis of full implementation of the assessment method specified in PAS 2050. Such
assessments should be verified by an independent third party organisation that is able to
demonstrate its compliance with ISO 14065 and which has certification to PAS 2050
within its scope.

Drafting note:

The Carbon Trust will work with verifiers to assure that the same bodies can verify
conformity with PAS2050, PERF and this Code so that verification is as efficient as
possible.

2 Principles for claims about product lifecycle GHG emissions

NOTES ON SECTION 2

The principles introduced in this section were not specified in draft 0-6 of the PECG, on
which this document is based. Principles 1 and 2 were reviewed by the Carbon Trust's
Reduction and Communication Steering Group in April 2008, which recommended to
include them in this section of the document. They are based on ISO 14020: 2001
Environmental labels and declarations - general principles.

Drafting note: The intent of this Code is that it should allow companies as much freedom
as possible in developing creative and innovative approaches in the use of declarations
and claims relating to reductions in product-related GHG emissions, consistent with the
stated principles, while assuring robustness.

2.1 General principles

Claims relating to the life-cycle GHG emissions of products should meet the following
general principles:

Principle 1: Claims shall be truthful

Claims shall be accurate, verifiable, relevant and not misleading.
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Principle 2: Principle 2: Claims shall support effective decision-making
Claims shall help consumers and companies make choices which will be effective in
reducing GHG emissions over time.

2.3. Specific principles

The general principles are supported by specific principles, as follows:

2.3.1. Claims shall be accurate

Estimates of product-related life cycle GHG emissions and/or reductions shall be based
on full implementation of the PAS2050 method for evaluating product-related GHG
emissions.

2.3.2. Claims shall be verifiable

Public claims shall be verified as specified in Section 1, above.

All claims should be substantiated by the publication of supporting information as

specified in Section 6, below.

2.3.3 Claims shall be relevant

Product-related claims about GHG emissions should be specific to the product about
which the claim is made.

2.3.4. Claims shall not be misleading

2.3.4.1 Claims based on the product's life cycle GHG emissions should be limited to the
issue of GHG emissions and shall not imply broader environmental impacts.

Example
• Companies shall not use GHG emission reductions to make generic claims that a
product is 'environmentally friendly' or 'better for the environment'.

2.3.4.2 Claims should not confuse low carbon emissions with reductions in carbon
emissions

Example
• A claim that a product is a 'low carbon product' because the manufacturer has
reduced its product-related emissions would be misleading unless the
manufacturer could present convincing additional evidence that the product's
absolute levels of emissions were low compared to other similar products in the
market, using the same method of measurement.

2.3.4.3. Claims should not imply that the product is associated with a reduction in GHG
emissions if the reduction would depend on changes in consumer behaviour which are not
demonstrable.

Example
• An on-product claim for an actual reduction in product-related GHG emissions
associated with a heating appliance would be misleading if the reduction
depended on consumers using the heating appliance at a lower temperature.

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3 Communicating quantitative information about product-related life cycle
GHG emissions
3.1 Declaring overall emissions
Claims relating to a product's life cycle GHG emissions shall be reported as a single figure
encompassing the total emissions for the product, taking account of all the phases of the
product's life cycle, in compliance with the specification of the PAS2050.

3.2 Declaring emissions of specific parts of the supply, or multiple PAS2050

results
Where it is considered relevant companies may also report:
a) emissions for individual phases of a product's lifecycle;
b) results based on different scenarios for a product’s sourcing, manufacturing, use
or disposal.

Example
• The carbon footprint of this product is 50g CO2e per functional unit, and 80% of
these emissions are associated with the normal use and disposal of this product.
• The carbon footprint of this product is 50g CO2e per functional unit. 80% of these
emissions are associated with the normal use and disposal of this product. These
emissions can be reduced by 10g CO2e per functional unit by drip drying rather
than tumble drying.

3.3. Units of measurement

3.3.1. Standard unit of measurement
Figures for GHG emissions shall be specified as mass of CO2 equivalent (CO2e) as
defined by PAS2050.

3.3.2. Functional unit

The product-related life cycle GHG emissions for the product shall be specified per
functional unit of the product. For services, or for goods delivering a service (e.g. a light
bulb delivering the service of supplying light) emissions should be specified as mass of
CO2e per unit of service provided.

Examples
• Product X has GHG emissions of 10g CO2e per 100g unit
• Each overnight stay at hotel Y is associated with GHG emissions of 10kg CO2e per
customer

3.3.3. Product unit

A company may report a product's life cycle GHG emissions on a product unit basis
provided that the result based on a functional unit is also presented.

Example
• Product X has life-cycle GHG emissions of 10g CO2e per 100g unit, or 50g CO2e
for the whole pack

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3.4. Result precision and rounding
The reported emissions shall be rounded according to the following rules:

Life cycle GHG emissions per functional Round to nearest

unit (CO2e/FU)
>10g, <=20g 1g
>20g, <=40g 2g
>40g, <=100g 5g
>100g, <=200g 10g
>200g, <=400g 20g
>400g, <=1000g 50g
>1.0g, <=2.0kg 0.1kg
>2.0g, <=4.0kg Nearest 0.2kg
>4.0g, <=10kg Nearest 0.5kg
Etc etc

Example
• A product whose overall emissions are presented in its Product Emissions Report
as being 58g CO2e per 100g unit would be referred to as emitting 60g CO2e per
100g unit in the context of a product label. An annual reduction of 6.5g CO2e per
100g would be rounded up to 7g. An annual reduction of 1.16g CO2e per 100g
(i.e. 2%) would be reported as a reduction of 1.2g CO2e per 100g.

Drafting note:

It is important to specify rules on the precision of the result, as there is high potential for
miscommunication if companies communicate product-related GHG emissions or
emissions reductions to different levels of precision.

The rounding bands for reporting the life cycle GHG emissions per functional unit are a
compromise between maintaining the precision of the calculation, and ensuring that
differences between results are apparent. For example, under this banding scheme, the
largest percentage change in the calculated “best estimate” for a product would occur
when rounding down a result of 45gCO2e/FU to 40gCO2e/FU, a change of 11% (similarly
when rounding 450gCO2e/FU to 400gCO2e/FU). In all other instances, rounding would
result in a lower impact on precision. Rounding to the nearest valid number in the band
(rather than rounding to the next highest number, or next lowest number, in the band)
reflects the expectation that uncertainty in the “best estimate” is uniform above and below
the best estimate.

The proposed bands are based on limited uncertainty analysis with pilot companies.
Additional work is being currently conducted and conclusions will be used to inform further
development of this section.

3.5. Up to date information

Declarations of emissions shall be kept up to date. Claims shall not be based on data or
information which is more than 2 years old, if this is likely to result in material change.to
the lifecycle GHG emissions of the product.

4. Communicating of reduction claims on product lifecyle GHG emissions

4.1 Compliance with PERF
Claims of reductions in product-related life cycle GHG emissions shall comply with the
requirements specified in the PERF.

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4.2 Basic reporting requirements
Any claim relating to reductions in a product's life cycle GHG emissions shall:

4.2.1.be based on repeated assessments of baselines using the assessment method

specified in PAS 2050;

4.2.2.include a statement of the actual baseline emissions, in compliance with the

requirements of section 3;

4.2.3.expressed in absolute and/or percentage terms compared to the initial level of

emissions; and

4.2.4.specify the time period over which the claimed reduction has taken place

Examples:
• The carbon footprint of this product is 50gCO2e per 100g serving. We have
reduced this footprint by 20% over the last two years.

• The carbon footprint of this product is 50g CO2e per [functional unit]. We have
reduced this footprint by 10g CO2e per [functional unit] over the last five years.

4.3 Supporting information

All claims shall include a clear reference (e.g. a website address) indicating where the
additional supporting information specified in section 5 (Product Emissions Report),
below, is available.

Example:

• The carbon footprint of this product is 50g CO2e per [functional unit]. See
www.ourcarbonfootprint.com for more information.

5. Reporting supplementary information about product-related life cycle GHG

emissions: the Product Emissions Report

NOTES ON SECTION 5

The content of this section has been updated to simplify some requirements that were
perceived as burdensome and unnecessary by some stakeholders (e.g. inclusion of
product category, manager accountable for carbon management and specific reduction
plans at the product level). It has also been updated to include other requirements that
were seen as necessary, notably the definition of the lifecycle GHG emissions of the
product and disclaimers on uncertainty.

Drafting notes

Note 1: On reduction plans

Several stakeholders commenting to the PERF have highlighted the difficulties of publicly
identifying reduction activities that may be commercial in nature. However the inclusion of
these plans/actions is likely to strengthen the credibility of the reduction claim. The
requirement is currently presented as optional.

Note 2: On Product Emissions Report and product definition

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Some stakeholders have commented that writing a Product Emissions Report for each
product in cases where a company has multiple products (e.g. retailers, or highly
diversified manufacturers) will be a significant burden. The definition of an appropriate
level of aggregation is being addressed by the working group currently developing a
“product definition” for the PAS, PERF and Code of Good Practice on claims. Clause 5.1
clarifies that a single report may be used to present information applicable to a range of
products.

Note 3: On requirement to disclose primary and secondary data sources

This requirement is necessary to assure transparency and consistency in the analysis
across companies. However, many assessments include a high number of data sources
(e.g. over 50 is not infrequent). Clause 5.4.2. applies the principle of 'materiality', that
sources should be identified that cover 95% of the total emissions.

5.1 Scope of the Product Emissions Report

5.1.1 Claims relating to product life cycle GHG emissions shall be supported by the
publication of a 'Product Emissions Report' which provides context and explains the basis
for the claim being made. The Product Emissions Report may cover one or more
products. Where more than one product is covered the report does not need to repeat
background information or references that are the same for several products, and may
present information for different products in the same report.

5.1.2 The Product Emissions Report shall provide an overview of the results, data,
methods, assumptions and limitations of the product-related emissions analysis for the
products it covers in sufficient detail to allow the reader to understand the complexities
and trade-offs inherent in the determination of the product's life cycle GHG emissions and
help assure consistency, following the requirements described below.

5.2 Background information section

The Product Emissions Report shall provide the following introductory information:
5.2.1. the name of the company producing or providing the product(s);

5.2.2. the specific product(s) whose life cycle GHG emissions are reported (e.g. Brand X
washing powder; Brand Y concentrated washing liquid; Z Hotel accommodation);

5.2.3. the specifications and/or other documents against which the company has been
assessed for conformity (e.g. the title, number and date of the BSI Publicly Available
Specification); and

5.2.4. the name of the body(ies) that have verified the company's conformity with the
requirements of PAS 2050, and with the requirements of this Code if applicable.

5.3 Company policy

The Product Emissions Report should specify the company policy and strategy in relation
to climate change, including:

5.3.1. a public statement/ policy identifying climate change as being relevant to its
business activities;

5.3.2. the company's medium-term and long-term strategy to reduce carbon emissions
across the company as a whole; and

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5.3.3. the company's target(s) to minimise GHG emissions across the company as a
whole.

5.4 Product emissions assessment

For each product covered by the following information shall be provided:
5.4.1. a description of the boundaries of the emissions assessment for the product and
the basis for the boundary decisions for the overall product and for its use profile;

NOTE: PAS 2050 identifies two potential sources for defining the boundaries for the
assessment of life cycle GHG emissions: i) the boundaries specified in a relevant Product
Category Rule (PCR), or ii) where a PCR does not exist for the product the default boundaries
described in the PAS 2050. The Product Emissions Report should refer to the source used for
the PAS 2050 assessment, and when they have not used a PCR, define broadly the
boundaries for the specific product under analysis.

5.4.2. the sources of secondary data which have been used for the assessment;

NOTE: this requirement requires that the sources of data should be disclosed, not the data
itself. Sources should be declared covering the material sources of emissions, i.e. 95% of the
total emissions.

5.4.3. the date(s) when the overall emissions were assessed; and

5.4.4. the quantitative results of the assessment (PAS 2050).

5.5 Supporting information relating to reduction claims

Companies making claims about reductions of their product(s)' lifecycle GHG emissions
shall include the following information in the Product Related Emissions Report:

5.5.1. Baseline
The Product Emissions Report shall disclose the baseline emissions figure as assessed
before the reduction took place (see PERF) and the subsequent emissions figure
assessed after the reduction took place.

NOTE: The figures for the two time periods should be presented in a common format which makes
comparison as simple as possible, for example as a table with columns presenting the data for the
baseline and subsequent date(s) side by side in the Product Emissions Report.

5.5.2. Reduction drivers

The Product Emissions Report shall include a description of the high-level actions that
have been implemented, or which are planned to be implemented, to reduce the life cycle
GHG emissions of the product. When the actions lead to savings that are to be banked
over time, a detail of the savings banked and time period shall be included in the Report.

5.5.3. Baseline updates

When the original baseline figure has been revised to reflect changes in PAS2050
versions or data, the revised baseline figure (using the new or updated information), and
subsequent results after reductions have taken place (also based on the new or updated
information) shall all be included for comparison in the Product Emissions Report,
together with an explanation of the changes in the baseline.

5.5.4. Force majeure

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If the company wishes to claim reductions taking account of 'force majeure' events (as
defined in the PERF) then it shall include a description of such events, together with an
explanation of the changes in the baseline in the Product Emissions Report.

5.7. Disclaimer about uncertainty of results

The Product Emissions Report shall include a disclaimer regarding the level of uncertainty
associated with the reported emissions results. The disclaimer could take the form of a
qualitative statement regarding the uncertainty of the results, or a quantitative assessment
of uncertainty.

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Annex 1
Product Emissions Report template

NOTES ON Annex 1

Several stakeholders have suggested that it would be useful to include a reporting

template, to clarify expectations in relation to reporting, to simplify the task of reporting,
and to improve consistency. This template is currently under development.

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