SIK Comments on:
CPC 8814
OILSEED PROCESSING SERVICE
2013:11
DRAFT VERSION FOR OPEN CONSULTATION
Section 6.1 General cut off rules and 7.2 Cut off rules
Comments on sentences:
“Furthermore, a minimum of 95 % of the impacts of any impact category (as defined in chapter
10.2) shall be included.”
“Contribute less than 5% of the total environmental impact for each impact category considered and/or”
How to know what is 100% before doing the assessment?
Section 7.1.1 Technical system
Why is the section of H2S emission included?
“On-site emissions of H2S per functional unit shall be approximated as follows for processing of the different
oilseeds:
Rapeseeds: 0,15 kg
Sunflower seeds: negligible
Soybeans: 0,02 kg”
The reason for this was not known to one of the world leading vegetable oil processing companies.
Section 7.1.5 Boundaries to other technical systems
The sentence: “The outflow of materials for recycling, heat recovery, landfill and waste treatment shall be
declared without assigning the environmental impact of the whole system” need to be clarified. Is “the whole
system” referring to the waste treatments, the core module or the whole PCR?
Section 7.3 Allocation rules
Comments on “For allocating potential environmental impacts of the service to the different products and byproducts, allocation based on the energy content (lower heating value) shall be used.” Allocation based on
energy content may be hard to get. The SCPRT’s Envifood Protocol recommend to apply economic allocation
for the food and drink sector using the average market value over a three year period.
Section 7.5 Rules for generic data
Clarify the sentence “Generic data used shall not exceed 10% of the core module life cycle inventory.”
How do you measure 10% of inventory? 10% of total input posts? 10 % of total weight?
Better expression: “The environmental impacts associated to generic data must not exceed 10% of the overall
environmental impact from the product system.”
Contradiction in Section 7.4, 8.2 and 9.2
Site specific data shall be used for the core module production site and generic data shall be used for energy
mix and wastewater treatment. If a company actively uses only sustainable energy sources and waste water
treatment technologies this will then not be shown in the PCR result. What will then be the driving forces for a
company to use the PCR? Will only amounts of energy use and waste water then matter?
Section 10.2 Potential environmental impacts
The suggested characterization method is CML providing impact units for each environmental impact category
as stated in the EPD General Program Instructions. This not in alignment with the other European
Environmental footprint initiatives (The EU commissions JRC Product Environmental Footprint & SCPRT’s
Envifood Protocol) that recommend the ILCD characterization methods and rule out comparability.
Section 10.5 Presentation of the LCA results
Not only the production BUT the use of energy is important.
SIK, 14th Jan 2014
Katarina Nilsson, PhD
SIK - the Swedish Institute for Food and Biotechnology
Business Manager, Sustainable Food Production
email: kn@sik.se