Try typing “Non-tariff Trade Barriers” into Google and you don’t find CAN/CSA-ISO 14021. How odd! Well, give it a year or so and see what happens. My guess is that Canada’s Department of Foreign Affairs and International Trade will have more than a few issues to deal with. The foregoing alphabet soup is ID for Canada’s new international standard for environmental marketing. The standard is the foundation of Plus 14021 – Environmental Claims: A guide for industry and advertisers, a new guide which will apply to existing Canadian laws. The Guide is published by the Competition Bureau of Canada, ironically, the federal watch dog on unfair commercial practices.
Plus 14021 is a good idea – as I’ve said before – in principle. But the devil is in the details and, if you’re in the building materials business, there are certainly some details worth noting in the section on Life Cycle Analysis (LCA).
The Guide defines Life Cycle, fairly, as “consecutive and interlinked stages of a product system, from raw material acquisition or generation of natural resources to final disposal.” Using the legal imperative, it states that environmental claims “shall take into consideration all relevant aspects of the product life cycle in order to identify the potential for one impact to be increased in the process of decreasing another.”
Before going on, I want to be clear that I am a staunch defender of an LCA approach to environmental claims, although perhaps not for expected reasons. If we were living a few hundred years ago, a single attribute claim might be perfectly acceptable. Our common understanding of “environment” would have then been narrow, local probably, and not the global environment we speak of now. In some contexts we might still speak of our environment in the old way, and therefore sometimes it might be acceptable to tout a specific environmental benefit without reference to every stage of the material’s existence. When one speaks of the environment today, however, it’s invariably with reference to the global environment, so the fact is we all live in a globalized world when it comes to thinking about the environment.
It’s therefore important to understand that there are certain necessary conditions that we must accept if we are even to speak of protecting the global environment, and one of these, fundamentally, is that we engage in international trade. There is a crucial question to answer then, whether shipping, the sine qua non of international trade, should be included in any Life Cycle Analysis respecting the environmental values attached to materials traded. I believe it should not, because to exclude it would be to recognize it for what it is, a basic assumption necessary to our discourse about the environment itself. This is not to say that international shipping cannot itself be improved upon to the benefit of the global environment (it is after all one of the world’s leading sources of green house gas emissions). It is to recognize instead that its environmental evil is a necessary one, and while its ill effects are reducible, they belong to a separate category from that of the cargo it moves.
We can now return to Plus 14021 which lists for our convenience the environmental impacts a Life Cycle Analysis of any product. I have bolded two points simply to make clear what I am arguing for, in one typical example, bamboo products from Asia, shipped by sea and imported into North America.
- design of the product
- extraction of any raw materials used in the product or process;
- materials (including energy) used in the production process;
- emissions created during production (air, water, solid waste, etc.);
- toxicity of these materials and emissions;
- environmental impacts of the distribution system (including packaging and transportation);
- environmental impacts that occur during use of the product or service;
- durability, reusability, and recyclability of the product;
- consumer packaging and its disposal; and
- final disposal of the product.
A vendor of bamboo flooring, for example, would naturally advertise that the material, in addition to its durability, is a rapidly renewable resource. It would therefore be promoted for green building points according to these attributes. Under Canada’s new guidelines, however, while not required to complete a full life cycle analysis to support this self-declared claim, the vendor would need “to consider the entire life cycle of the product to ensure that there is a net environmental benefit.” And this as you can see from above, would include the transportation of the flooring from Asia to North America. It would likely be hard to offset the shipping pollution when comparing the Asian bamboo flooring to a North American hardwood. Standards like LEED give green building points for locally harvested or manufactured materials, as well as for those made from resources like Bamboo, despite its shipping distance. Canada’s Plus 14021 will impede international trade, and I think Canada is wrong in its approach.