ON-SITE VS. LIFE CYCLE REQUIREMENTS
LPC asks manufacturers to measure the impact of production at two scales – on-site at the final manufacturing facility, and within the life cycle of the product. This encourages manufacturers to identify opportunities for impact reduction both on-site, where they may have the most control over efficiency of water use and building closed loop systems, as well as within the product’s life cycle by identifying key drivers of impact (hotspots) and engaging with the suppliers to reduce their impact, or identifying suppliers more aligned with their sustainability goals.
Some final manufacturing facilities comprise a significant portion of the cradle-to-gate life cycle impacts of a product, in other cases final facilities will only conduct light assembly and may not use water at all. The combination of these two scopes ensures that the full water impacts of a product are captured, regardless of whether production is vertically integrated or not.
ON-SITE (FINAL MANUFACTURING FACILITY) CLARIFICATIONS
Final Manufacturing Facility (On-Site)
“On-site” within LPC refers to the final manufacturing facility, which is the final location where the product is physically altered (i.e. final point of assembly). If the final point of assembly represents multiple locations (i.e. facilities producing the same product in multiple geographical regions), the manufacturer must identify which of these is included in the certification. If a customer cannot distinguish between products produced at each of the facilities, or ensure that selected products are from a facility that has undergone an audit, the manufacturer must include all relevant facilities in the certification.
Site Performance Period
The site performance period should reflect documentation of water usage over a 12 month period. Manufacturers should use a consistent period of time that aligns with performance in other Imperatives. Data should be taken from a 12 month period within the 24 month period prior to submittal of audit documentation.
A manufacturer may certify a new product line or collection with fewer than 12 months of production data, but should first consult with ILFI or an Assessor to confirm that they will have adequate information to document or accurately predict key product metrics. Annual check-ins that take place with the Assessor post-certification additionally ensure that manufacturers continue to meet the requirements of the program throughout the period of certification.
On-Site Process Water
Process water is defined as water required to produce the product at the final facility, including but not limited to water used for material production (e.g. producing foam or dyeing), machine operation, or rinsing.
Manufacturers are required to identify the sources and fate of all process water in order to identify opportunities to increase on-site renewable water sourcing, potable manufacturing water use efficiency, water reuse and recycling, non-potable water use, and on-site effluent treatment and disposal.
The process water volume should be determined through traceable data, not limited to reviewing monthly data and bills from the 12-month performance period, from meter(s) and submeters, other onsite tracking systems. Manufacturers should clearly describe how they calculated both the production water use (submetering is preferred), as well as how they calculated the product’s share of facility functions.
If the Product Share Pathway is used (LPC production at the facility accounts for <75% of output by cost or volume), only process water associated with production of the product(s) pursuing certification must be accounted for. If the Whole Facility Pathway (LPC production accounts for >75% of output by cost or volume) is instead pursued, all water associated with manufacturing on-site would be included in the scope.
If no water at the facility is used toward manufacturing processes for the product pursuing certification, the manufacturer must document this through a manufacturer statement. and the product is considered to have met the requirements of site “Net Positive”. The claim will be confirmed during the site audit.
Implementing On-Site Efficiency Opportunities
Manufacturers are asked to identify opportunities for more efficient use of potable water in the production process as well as further opportunities for closed-loop water use on-site. They must implement and document at least one action by the time of certification and quantify its impacts.
LIFE CYCLE CLARIFICATIONS
Valid LCA
Water footprint data for products pursuing the Living Product Challenge come from LCAs completed to guidelines in ISO 14040 and 14044, or from Type III facility-specific or product-specific cradle-to-grave Environmental Product Declarations completed to a relevant Product Category Rule that are published by product manufacturers/declaration holders, or published by ISO 14025 program operators that have completed the third-party verification and registration of the EPD, as defined in ISO 14025, ISO 14044, and ISO 21930 and/or EN 15804. The LCA must have been completed and/or critically reviewed by an Approved LCA Practitioner (see below) and be made publicly available. The American Center for Life Cycle Assessment (ACLCA) maintains a list of active LCACPs.
An existing LCA may be used if it is still valid. However, manufacturers should note that they may have to further analyze the results or re-engage a consultant who created the LCA in order to discover required program information (e.g. Energy Hotspots) or to better reflect any Footprint reductions that have taken place.
Approved LCA Practitioners
All manufacturers must produce and maintain an LCA report demonstrating the product’s cradle-to-grave impacts, performed in accordance with a relevant PCR (if one exists) and ISO 14040/44 and meets the following:
- Has been critically reviewed by a third party for conformance with IS0 14044
- Has either been performed by an LCA Certified Practitioner certified by ACLCA or by an ILFI-approved LCA practitioner or consultancy.
The American Center for Life Cycle Assessment (ACLCA) maintains a list of active LCACPs.
For EPDs, the ACLCA maintains a list of active ISO 14025 program operators.
Industry Average Footprint
Product manufacturers must identify the industry average water footprint value and identify whether they fall above or below that value.
Acceptable methods for documenting an industry average are presented below, in order of preference:
- Manufacturers can submit a known industry average, industry-wide or sector LCA or EPD commissioned and completed by their industry or trade association(s). The sector LCA or EPD should reflect the same geography as the final facility, or the final facilities respectively.
- If a product-specific industry average LCA or EPD does not exist, manufacturers may use a broader product type LCA or EPD that still represents the product seeking certification. Industry average LCAs or EPDs should be used for comparison purposes and relative performance only and does not take place of any other documentation related to product environmental impacts.
- Three competitor product EPDs may be used in the absence of any established industry averages, if they use the same PCR and background data, impact assessment methods and assumptions are adequately comparable.
The manufacturer must provide rationale for the type of industry average referenced based on the industry landscape. If no industry average exists, the manufacturer must note this and provide a brief narrative regarding efficient use of water throughout the life cycle relative to similar products and identify opportunities for improvement.
Establishing a Footprint Baseline
The water Footprint baseline per functional unit should be established based on the most recent valid LCA data for the product. To establish the scale of water impact required to be offset through Handprinting, the manufacturer may use predicted sales volume for the three years of certification. If those values are too high or too low, the manufacturer may use the annual check-ins with their assessor to “true up” Handprinting impacts.
