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 and ability to maximize renewable energy, 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 or may not use energy at all. The combination of these two scales ensures that the full fossil energy impacts of a product are captured, regardless of whether the manufacturer is vertically integrated or not.
ON-SITE (FINAL MANUFACTURING FACILITY) CLARIFICATIONS
Site Performance Period
The site performance period should reflect documentation of energy 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 last 24 months prior to the certification audit.
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.
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 may take place at different multiple locations (i.e. facilities producing the same product in multiple states), 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.
Process Energy (Product Share Energy Scope)
Manufacturers using the Product Share Pathway (where LPC production accounts for <75% of facility output by cost or volume) must only offset fossil energy use associated with manufacturing the product that is pursuing certification.
Process energy refers to the energy required to produce the product on-site at the final manufacturing facility. This includes all production-associated energy (machine operation, power tools, heating for steam production).
The on-site energy footprint should be determined through traceable data from meter(s) and submeters, other onsite tracking systems or web-link to an online mechanism that clearly records energy produced and consumed (e.g., total energy generated; total energy use by subsystem including simulated/designed demand if available). Manufacturers should clearly describe how they calculated both the production energy (submetering is preferred).
If the Whole Facility Pathway production accounts for >75% of output by cost or volume) is instead pursued, all fossil energy use on-site would be included in the scope.
If no fossil energy at the facility is used toward manufacturing the product, the manufacturer must document this through a manufacturer statement and the product is considered to have achieved 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 fossil energy use on-site. They must implement and document at least one action by the time of certification and attempt to quantify its impacts.
LIFE CYCLE (FOOTPRINT) CLARIFICATIONS
Valid LCA
Energy footprint data for products pursuing the Living Product Challenge come from life cycle assessments 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 all of 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
The American Center for Life Cycle Assessment (ACLCA) maintains a list of active LCACPs. The list is not limited to LCACPs in North America or the Americas.
For EPDs, the ACLCA maintains a list of active ISO 14025 program operators.
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.
Industry Average
Product manufacturers must demonstrate that their product’s fossil energy footprint is below the industry average, or take steps to bring the footprint below the industry average prior to certification.
Manufacturers can submit the 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.
If no industry average exists, the manufacturer must note this and provide a brief narrative regarding efficient use of fossil energy throughout the life cycle relative to similar products and opportunities for improvement.
Establishing a Footprint Baseline
The fossil energy Footprint baseline per functional unit should be established based on the most recent valid LCA data for the product. To establish the scale of fossil energy 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 if they are too low, or establish how much is in their Handprint bank.
