Product design, standards and innovation

Product design is something that is no longer ‘just a good idea’. Creating a sustainable product is also an important trigger for your product design.  But then it gets boring – you start to take stock of the standards and think – we are trapped!

The backdrop is the lower slopes of Mount Kosciuszko (arguably the highest mountain in Australia), and it is winter. Looking into a log fire and being thankful we were warm and safe it was discussed that a better design and innovation are difficult to commercialise. The desire, the plans and even the Research and Development phase is proven. The issue at hand is the ‘bankable’, the intellectual protection and the confidence needed for the buyer of the new product. The buyer quickly becomes the focus. Then you divide it into whether the domestic market is different to the international market, and that leads to what standards might affect your design.

This means you either consider the process of manufacture as a pure design or as a managed procedure or both. Examples being:

The ISO 9000 series – It has a purpose of being a quality management system and China is issued the greater number of certificate holders in the world. Then comes the reasons for not adopting this standard and this would include the risks and uncertainty of not knowing if there are direct relationships to improved quality, and what kind and how many resources will be needed. Then there is how much certification will cost, the increased bureaucratic processes and risk of poor company image if the certification process fails.

The ISO 14000 and ISO 9000 series is similar in that both are concerned with the process of how a product is produced. However, it is worth noting neither is concerned with the product itself.

Importantly for this ‘fire side’ discussion ISO 14000 standards main aim is to assist companies in continually improving their environmental performance, whilst complying with any applicable legislation.

What is the better way to go? Why do it at all when you want to establish your reputation on product performance? Simple answer if you want to sell it on mass and to certain markets it is important that you focus on at least one standard. The decision required is whether to do it as a quality of process management or as a management focus on environmental performance and applicable evolving legal compliance and reporting duties.

If you have followed carbon management and the principles you will have understood the trends and the effects of the product needs to promote through Life cycle Assessment, the product footprinting, and governance requirements. In Europe in particular PAS 2050 cannot be ignored. If that is where you market is heading you might be even more interested to know ISO/TS 14067 is the story of today.

Product footprinting is standard ISO/TS14067 (ISO = International Organization for Standardization, TS = Technical Specification. The full name of the standard is: ISO/TS 14067 – Greenhouse gases – Carbon footprint of products – Requirements and guidelines for quantification and communication.

The genus: Built on ISO14040 and 14044. And originally they were known as LCA standards. LCA originated around 1997 and replaced around 2006. Academically and professionally, these are very well understood and in use.

The fit: It uses the existing terminology, concepts and ideas from 14044 and builds from this and what you learnt before will be understood today. It is comparable to the Greenhouse Gas (GHG) Protocol and PAS 2050 and is related to many industry and government agency specific guidelines.

What is different:

Expanding from the original LCA to ISO/TS 14067 brings in the requirements for providing, quoted is

 “principles, requirements and guidelines for the quantification and communication of the carbon footprint of products (CFPs).” Four types of communication are identified:

  • CFP external communication report
  • CFP performance tracking report
  • CFP label
  • CFP declaration


Of particular interest is that a performance tracking report …allows for the comparison of CFP results of one specific product of the same organization over time with respect to its original or previous CFP”.

The consensus: PAS 2050 was declared, ISO/TS14067 was built with international consensus representing about 50 countries through 12 working group meetings.

The importance of data:

A lot of data has already been collected for comparing product and categories are created that align with most products ‘norm’ for carbon footprinting. In short you can research if you don’t have enough data to start and the specification defines that the “best quality data available” should be used. Where site-specific data cannot be practicably collected, verified process data should be used. How good is that? A bit different to the ‘you shall’ or the sky falls in sort of thinking.


To conclude and quote Supply Chain: We should look at the standard as “

  • Something old = Built on the accepted ISO 14044 standard
  • Something new = Extends the scope of requirements for the communication of LCAs – which may be the next logical step for your current LCA work
  • Something borrowed = Utilises existing Product Category Rules concept that you may already be complying with
  • Something blue = Utilises process data that you may already have”.


In context to the original opening ‘discussion’ yes it makes sense that if you want to future proof you product or you want to move to markets where adopting EU stewardship rules, you have to consider it part of your plan to participate.  Just maybe that way you could break the ‘Business as Usual’ cycle and or hindrance to innovation.



Real, Additionality, RECs

Observing CTi’s Carbon Offsets 2 day Masterclass offering, it occurred that a US based mob was on about getting real about ‘real’ carbon offsets. Curiosity lead to checking out the reporting standard AS/NZS ISO 14064, finding it is silent on the word or term ‘real’ and completely avoids the topic of additionality, was fascinating given that you can’t even conceive of an offset without the concept of additionality!

CO2Land org now ponders: If ‘real’ cannot be a guarantee of a good project outcome. It follows that the use of the word or term ‘real’ can be seen as a initial or promised activity increase and not be seen as a guarantee of an increase in the carbon offset (it could be real activity and still lead to a decrease of carbon offsets). So if I say it was real at the time I acted; it was an act in good faith only. The issue with the word ‘real’ is it literally means the activity is a cause of change.

This lead to thinking of the impact this has on the Carbon Farming Initiative as legislated when the Gold Standard and Carbon Fix require that projects be “real”, but no international standard could explain what they mean by using the terms.

Now lets talk of the other mob: In their story –

Getting real about “real” carbon offsets,  by Michael Gillenwater –it was said:

“The qualities of a good emission offset project are one of the most common refrains you hear in the carbon offsets community. You can probably repeat most of them by memory: real, additional, permanent, verifiable, etc. Different programs or protocols might add other points about leakage or accuracy, or conservativeness or some other offset quality principle. But common to almost all programs and standards and protocols is the criterion that offset projects or credits must be ‘real’. Here is a question for you: What does it mean for an offset project to be real? What would an unreal offset project be? How could we tell if it was unreal, and is this something we should be concerned about?”

They go on to look even closer at the word or term ‘real’:

If you check out the Offset Quality Initiative and how they express the term ‘real’ and explain it the word should be done away with entirely as it is not meaningful, or at least ambiguous, and those that use the term are employing vacuous language. They claim the problem for ‘real’ is it most likely used to describe itself is real, and used this way one cannot ban imaginary projects, and one may ‘forward credit’. That is you can issue a credit before emissions have been achieved.

They continue that where ‘real’ is covered with a contrived definition and includes the concepts of completeness and accuracy in accounting, and leakage. It does so as no more than use ‘real’ as a synonym!

Now how do the markets act responsibly on handling this issue:

  • The Clean Development Mechanism (CDM) rules states that offset projects must be “real” in various places, but the definition is absent.
  • The Verified Carbon Standard (VCS) does attempt to handle this and goes with the imaginary friend test: All the GHG emission reductions and removals and the projects that generate them must be proven to have genuinely taken place. Much better description than using ‘real’ – no room for weasels in this one.

CO2Land org looked a little harder (we don’t want this post to be no more than ‘hot air’) and found:

  • Specifically ISO 14064-2 (project accounting) does not include ‘Real’ because during development of ISO 14064-2 ‘Real’ was regarded as a programmatic rule/criteria, which is outside the scope of ISO 14064-2.
  • ISO 14064-2 is a standard rather than a program
  • ISO 14064-2 (Clause 5.4) specifies the following requirement in regards to additionality: “The project proponent shall select or establish, justify and apply criteria and procedures for demonstrating that the project results in GHG emissions reductions or removal enhancements that are additional to what would occur in the baseline scenario.”
  • Additionality is incorporated into ISO 14064-2 is based on the core principles of ISO standards in general, i.e. that ISO standards not be a barrier to trade (WTO-TBT – anyone following development of ISO 14067 (product) will know this is a major issue). As such, ISO standards must be policy-neutral (extended to include program-neutrality). This is of course very important for market confidence.
  • ISO 14064 deals with the concept of additionality by requiring that the GHG project has resulted in GHG emission reductions or removal enhancements in addition to what would have happened in the absence of that project. It does not use the term “additionality”…Thus the project proponent may apply additionality criteria and procedures, or define and use boundaries consistent with relevant legislation, policy, GHG programmes and good practice.”
  • Although the concept/requirement of additionality is within the requirements of ISO 14064-2, the simple reason why the ‘term’ additionality is not present within the requirements of ISO 14064-2 is because of certain sensitivities/perceptions/politics of certain parties involved in the development of the standard –

And, the following references helpful in gaining a more complete understanding:

CO2LAND armed with this information focused more on Australia, and with raised eyebrows takes note ‘real’ is long-overdue for a critique of the ‘real world’ of concepts and terminology defining emissions offsetting and accounting policy and practice. In fairness what becomes obvious is domestically and internationally in Australia have had to deal with the vagaries of the debates and arguments over the development of both an international REDD mechanism and revision of accounting rules for land use, land use change and forestry (LULUCF) by Annex 1 countries.

Dealing with this is not as making the concept closer to simplicity and ‘naturalness’ in terms used as much of the confusion stems from failure to separate out responsibilities for project managers, national/sub-national regulators and for the international community. In short the levels of responsibility presume everyone else should be responsible for everything. Then everything ‘real’ becomes perverse. Source: Alistair Graham
Tasmania, Australia
7 August 2012

Previously CO2Land org has written of the perils of the REDD issues, and that things are going to avoidably get more complex, and Alistair Graham also believes we best get our house in order for the, relatively easier stuff in the non-LULUCF sectors.

Then rock my socks along comes Judith Hull (talking of work with Environment Canada) and commented, August 13th, 2012:

“Michael – In response to your August 9 note on my short comment, I would emphasize that isolating one criterion is always problematic. Clearly baseline setting with functional equivalence is key. We used the ‘real’ criterion to flag that just a cut in production would not be eligible. A project to make that production more efficient (even if total output were to decrease) may well be eligible. Judith”

Is it ‘real’?


There are a few other terms bandied about incorrectly.

1) RECs are not offsets. Yet routinely you hear they “have offset their carbon emissions with RECs.” That is wrong on several levels. Yes, it is inconvenient that the word offset can be a verb or a noun. But get it right. RECs can be said to “compensate for” or perhaps “balance” the GHG emissions from electricity consumption, but leave offsets out of the conversation.

2) While we’re hammering RECs, if a facility/organization is buying RECs they are not “powered by wind.” There is no orange extension cord connected to a wind turbine. RECs connect load to renewable power by a contract, not a wire. To say “powered by wind” creates false images in lay peoples’ minds.

3) If a facility/organization is buying offsets or RECs sufficient to equalize all their GHG emissions, they have not attained “climate neutrality.” They have attained “GHG neutrality.” The definition is “no net GHG emissions.” That definition does not define a state of the climate, it defines a state of emissions.

It is wrong to connect climate with RECs – RECs like green power energy are project outcomes.


REC References: