Ambiguous assessments: problems afflicting lifecycle assessment

24th November 2022

David Burrows delves into some of the issues with lifecycle assessment – and how brands are misusing results

Making green claims used to be easy. Opportunities were plentiful, rules were lax and consumers didn’t have a clue. However, 2022 presents a very different landscape for brands wanting to make such claims, with Tesco and Oatly among those that have got into trouble for greenwashing in recent months.

The supermarket chain was scolded by the Advertising Standards Authority because it couldn’t provide the full lifecycle evidence to back up claims that its plant-based burgers were better for the planet. Oatly, meanwhile, had done those lifecycle assessments (LCAs) for adverts relating to the impact of its dairy-free drinks compared to milk – but it wasn’t enough. It was a classic case of over-claiming, according to Advertising Standards Authority director of complaints and investigations Miles Lockwood. “Just because your product is probably better for the environment […] doesn’t let you off the hook for being accurate and being precise,” he told the Adventures in Coffee podcast.

The bar, it seems, is higher than ever. The Competition and Markets Authority has produced a new green claims code to help companies and is on the hunt for big firms that fall foul of the rules (it’s currently unpicking claims being made by ASOS, Boohoo and George at Asda). “It is no surprise that regulators are looking for green claims to be backed up,” explains Laura Kirwan, lead sustainability co-ordinator at food data company Nutritics. “LCAs are a method of doing that.”

Higg’s hiccup

The trouble is that it’s not just the claims under scrutiny – it’s the LCAs. If done well, an LCA can help a business to defend regulatory challenges, explains Anne Marie Taylor, director at law firm DWF. However, LCAs are frequently done badly, using data that will produce the company’s preferred answer, failing to consider the full lifecycle of impacts, or offering no transparency or independent review of the process.

To understand why this happens, why not all LCAs are bad, and how we can make the good ones better, it is important to consider what an LCA is and isn’t.

The assessments are calculations that aggregate environmental impacts (global warming potential, eutrophication, water use and so on) across the stages of a product into a single metric. “They are based on science, but it is not a scientific method,” Kirwan says. “It is an accounting method.”

As such, they are useful tools for businesses that are seeking to count their carbon as they set net-zero targets and embark on reduction plans. However, they are also in fashion because of their role in backing up green claims, including eco labels. One of the six principles of the Competition and Markets Authority’s code is that “claims must consider the full lifecycle of a product or service”, but this is easier said than done.

The fashion industry’s use of the Higg Materials Sustainability Index (Higg MSI) is a case in point. The index, a set of five tools launched by the Sustainable Apparel Coalition in 2011, was designed to measure and compare the environmental impact of different materials’ LCA data. Companies wanted a tool to help them do LCAs – one that would avoid completing time-consuming and costly new assessments for every product, but allow them to better understand their impacts and where to focus their actions. Sensible stuff.

However, last year, brands started using the index on consumer-facing labels and the whole thing came unstuck. In June, Norway’s Consumer Protection Authority moved to ban the index’s use in marketing to consumers, stating that outdoor clothing brand Norrøna was breaking the law by marketing its clothes as environmentally friendly based on the Higg MSI.

“Brands have been operating with one eye open and one eye closed for years”

The index doesn’t cover the full impact of a garment bought in a shop and is based on average figures, so the information was misleading. The retailer was, for example, promoting an organic cotton T-shirt as having significantly less impact than a regular one, but had “no grounds for such a claim”.

The Sustainable Apparel Coalition has quickly paused the consumer-facing part of its programme, stating that it was “fully committed to the use of standardised data to empower better decision making” but recognised “the additional challenges that come from translating LCA data to consumer facing information”.

“It is the quality of the data that goes into an LCA that determines the quality of the output”

It was the application of the LCA data that presented the problem. “I think the intent was positive,” says Karine Kicak, associate director at sustainability consultancy Anthesis – but she adds that there wasn’t the necessary level of rigour, including peer review, that would enable the index to be used to make public claims.

Scrutiny welcomed

Given the index’s global reach and the reliance on LCAs more widely to help steer consumers, businesses and governments towards environmental sustainability, the ripples from this could spread far and wide.

LCAs only measure environmental impact, not sustainability as a whole.This means they may obscure the true sustainability of activities such as organic cotton farming

LCA practitioners are all too aware of the assessments’ pitfalls: the assumptions that they need to make, the gaps in the data (forcing them to use secondary instead of primary data) and the sketchiness of the standards. The reality of consultancy life is that you are not paid for three years to do an LCA, as an academic might be, suggests one senior industry expert. That doesn’t produce a bad study, but the assumptions being made need to be transparent, they add.

Anyone who does an LCA should be happy for other people to “poke it”, suggests Simon Gandy, technical director at SLR Consulting. They should also be ready to “get criticism where things have not been done fantastically”.

It’s certainly clear that the Higg MSI has several flaws, which were brutally exposed when the application of the data shifted from internal decision-making to external and promotional material. It isn’t the only approach being scrutinised. “From the Higg MSI to brand and manufacturer websites, claims are made based on LCAs that are not available to the general public,” wrote Veronica

Clothing companies have come under fire for using the results of LCAs in customer-facing materials
“LCAs are based on science, but it is not a scientific method. It is an accounting method”

Bates-Kassatly, who interrogates the data behind sustainability claims. “And this is highly problematic.”

Her recent white paper, The rise of life cycle analysis and the fall of sustainability, written with professor Dorothée Baumann-Pauly of Geneva University’s Centre for Business and Human Rights, notes that

“it is the quality of the data that goes into an LCA that determines the quality of the output. Only if the data are representative and reliable are the outputs meaningful.” If that isn’t the case, consumers, investors, businesses and even policymakers can be misled. Well-intentioned legislative measures may even increase global warming, they warned.

The focus shouldn’t be limited to carbon, either. There is interest, for instance, in how LCAs could account for the environmental impacts they currently miss. “Marine pollution isn’t really covered under LCA, yet we know that’s a massive environmental issue,” explains Simon Miller, co-founder of sustainability consultancy 3Keel. LCAs do consider environmental factors such as land use and water, says Pauline Op de Beeck, associate director at the Carbon Trust, but “we’ve not yet found a robust and meaningful way to communicate these results to the public.”

It’s easier to measure fewer things, but as Baumann-Pauly suggests, “we have got to be ambitious. Just because it’s complicated, doesn’t mean that you can’t do it.” Data needs to be better, she adds. “Brands have been operating with one eye open and one eye closed for years.”

There is also the fact that LCAs only measure environmental impact, which has led to ‘sustainability’ being narrowly defined as ‘environmental sustainability’. Social dimensions are overlooked, and considering them can lead to very different conclusions. Take organic cotton. Environmentally, such a production system could make sense – but the farmers on organic smallholdings “have to work longer and harder and still produce less, their productivity goes down, they earn less and are trapped in poverty for longer,” notes Baumann-Pauly. Research she did last year found “not a single robust independent study anywhere that shows that organic farmers end up better off than their conventional neighbours.”

Shaken and stirred

The likes of SLR are working on how to integrate social dimensions into their assessments, while the OmniAction initiative aims to wrap more and more metrics into a holistic assessment of foods, eventually producing a consumer-facing label. “Consumers have a right to know this stuff,” says founder Lise Colyer.

“I think it’s healthy to shake things up,” adds Baumann-Pauly. “We will continue stirring.”

David Burrows is a freelance writer and researcher.

Image credit | Shutterstock


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