Determining which suggestions are related to the horizontal standard EN 16751 described below and which address additional topics was important in this regard. As an example, most of the suggestions we received regarding EN 16751 referred to issues for which a common, horizontal solution for all groups of bio-based products is unlikely. The responses also focussed on LCA, a topic covered by the standard EN 16760. LCA is also important for comparing bio-based products with fossil-derived ones, and this is currently also not covered by the narrow scope of EN 16751. Therefore, we also consider this topic separately.
3.3.1. Suggestions Related to EN 16751
The standard EN 16751 Bio-based products–Sustainability criteria was developed by CEN TC 411, whose main goal is to provide standards for horizontal aspects of bio-based products [53
]. The IEC defines a horizontal standard as a standard on fundamental principles, concepts, terminology or technical characteristics, relevant to a number of technical committees (see IEC Guide 108). These standards also have the purpose of avoiding duplication of work and contradictory requirements [54
]. According to ANSI, these general, basic standards are to distinguish from vertical, also called application standards.
As the focus of TC 411 is on horizontal standards, it has no intention to present threshold or default values. This is left to specific product standards or political decisions [53
]. In this context, we also learned by our interviews that experts distinguish between the system-based approach of horizontal standards and the more performance-based approach in standard setting.
Experts at standardisation committees suggested to develop assessment methods and thresholds for the criteria of EN 16751. Threshold values can be used to check conclusively whether a specific indicator was fulfilled based on measurable and quantifiable parameters. Based on the product-independent focus of this horizontal standard, opportunities to define common evaluation methods and corresponding thresholds are limited. Nevertheless, there are potential exemptions. There are issues that are relevant for the assessment of bio-based products in general, and there are also requirements which can be specified easier than others.
Depending on the specific nature of a criterion and its respective indicator(s), there are areas in which fulfilment requires the definition of threshold values. In other areas, fulfilment can be proven with a simple yes/no condition. Requirements, which can be easily specified by such a simple condition, refer in particular to social and economic criteria, for example to the requirement “no child labour”. Therefore, it is important to check the potential to define requirements on a horizontal level whenever possible. Furthermore, suggestions for common yes/no conditions regarding the use of grassland and forests are described at the end of this Section. These are especially relevant for the first life cycle stage of bio-based products.
During our information exchange with the experts interviewed, it was also communicated that economic sustainability is undervalued within EN 16751. In addition to this, our interview series with standardisation experts showed that the adoption of EN 16751 in product-specific standards is not as it should be. According to the understanding of an expert, only a bio-based solvent standard (drafted as EN 16766) and a surfactant equivalent (CEN/TS 17035) contain a requirement to use EN 16751 to show sustainability characteristics in Europe. More standards with a similar requirement would contribute to the promotion of sustainability criteria and stimulate their application. Closer collaboration with the TCs working on vertical standards for bio-based products is suggested.
3.3.2. Standardisation Issues beyond the Scope of EN 16751
This sub-section summarises eight additional suggestions for further standardisation work by standardisation committees and their representatives.
1. Provide assessment methods and thresholds for the criteria of EN 16751, if they cannot be defined via horizontal standardisation
As mentioned briefly before, the development of a certification scheme for sustainable bio-based products requires thresholds based on specified assessment methods. Experts interviewed emphasised that the specification of the assessment methods themselves had also not been carried out yet. Therefore, it is suggested to regard the work on assessment methods and thresholds as a high priority. Considering that the scope of EN 16751 excludes the establishment of “thresholds or limits”, additional standards are needed. A specific issue in this regard is also the fact that EN 16751 will not be updated before 2021 due to CEN’s review period of 5 years for EN standards. Separate standardisation work might also provide faster results in this regard. A standard providing general assessment methods may be created by the same CEN TC/411, while the TC’s scope requires that the specification of thresholds is carried out by other TCs in any case.
2. Provide assessment methods and thresholds for ISO 13065 criteria: if necessary, by additional standards
Specifying assessment methods and thresholds, the sustainability standard ISO 13065, developed by ISO/PC 248, can provide various advantages. The results could also be used as examples and foundation for further standardisation efforts in the field of bio-based products. According to an expert, ISO/PC 248’s output should be developed further regarding “criteria that can be evaluated quantitatively and qualitatively and specific levels of sustainability”. Nevertheless, he described the challenge of creating levels of sustainability in such an overarching standard that they are suitable for all feedstocks and continents. It was impossible to agree on thresholds in this standard besides providing examples in its annex.
Two solutions are suggested in this regard. The first one refers to the development of very generic indicators which facilitate a basic level of international consistency.
In addition, appropriate coordination between horizontal and vertical standardisation activities is important. Suggesting and assuming the development of additional standards in this regard, an expert added that the creation of a more specific standard based on ISO 13065, e.g., “for a certain fuel from a specific feedstock in certain climatic conditions”, could facilitate the determination of such threshold values. Such standards would provide the opportunity to add “a lot more detail and potentially even thresholds”.
3. Facilitate a cradle to grave or cradle-to-cradle analysis of bio-based products
EN 16751 has a restricted scope that considers the life cycle stages (“feedstock” and “production” or “cradle” to “gate” only). Advantages of bio-based products further downstream are therefore not recognized. An example, an interviewee illustrates this as follows: “A biodegradable bio-based plastic has an EOL option that emits short cycle carbon only. A petrochemical plastic that is biodegradable contributes to net long cycle carbon emissions as it is decomposed. On the other hand, the energy needed to produce the petrochemical plastic may be much less than an equivalent bio-based plastic. Moreover, if non-renewable energy is used in the production of a bio-based product this may lead to greater (fossil) carbon emissions. This sort of impact (e.g., carbon balance that spans the entire lifecycle) is not currently supported”. The interview series led us to suggest the creation of a basic cradle-to-grave standard, which also considers the EOL stage, or, if possible, even a cradle-to-cradle standard, which also considers circular issues of bio-based products. The circular aspect will be also discussed later in this section.
4. Provide a standard which facilitates comparisons of bio-based and fossil-derived products
As the previous section has partly shown, expert suggestions to specify assessment methods for EN 16751 were linked with comments on the relevance of comparisons with fossil-derived products regarding the three sustainability pillars and entire life cycle considerations. Currently, a comparison between both kinds of products based on EN 16751 is not possible. This standard explicitly excludes fossil content, although, for example, social and economic impacts could be compared relatively easily.
As an example of the advantages of a new standard in this context, an expert mentioned that bio-based solvents can have superior characteristics compared to fossil ones. Further research by the authors identified the solvent Cyrene as a good example for this. It can be directly derived from waste cellulose in two simple steps, therefore having a high stoichiometric biomass utilization efficiency. CyreneTM has demonstrated a similar solvent performance to toxic fossil-derived solvents, whose industrial synthesis involves multiple reaction steps (see [55
Several superior characteristics of bio-based products in general have even been highlighted by the European Commission: “(…) higher process efficiency can be obtained (in the production of bio-based products), resulting in a decrease in energy and water consumption, and a reduction of toxic waste. As (bio-based products) are derived from renewable raw materials, (they) can help reduce CO2 and offer other advantages such as lower toxicity or novel product characteristics (e.g., biodegradable plastic materials)”.
An additional specific example for superior characteristics is provided by smart drop-in chemicals. These chemicals are chemically identical to existing ones, but their bio-based pathways provide advantages. Carus et al. 2017 ([56
]) uses the term ‘smart drop-ins’ if at least two of the following superiority criteria apply: the biomass utilization efficiency from feedstock to product is significantly higher compared to other drop-ins, and/or compared to all alternatives, their production requires significantly less energy and/or their time-to-product is shorter due to shorter and less complex production pathways and/or less toxic or harsh chemicals are used or they occur as by-products during their production process.
These examples show the superior characteristics of bio-based products clearly, both in general, and with respect to specific product groups. Therefore, a standard which facilitates demonstrations of these advantages would promote their market up-take or, as an interviewee formulated it, “promote the market and strengthen (the) trade (of bio-based products)”. Nevertheless, experts describe that the comparison of upstream environmental impacts is not suitable, given the very different feedstocks. As a solution, we suggest discussions in CEN/TC 411, together with stakeholders of specific bio-based product groups (for example producers and public procurers) in this regard. If facilitating comparisons with fossil-based products by a horizontal standard appears to be difficult, information exchange on the level of product standardisation is important to create synergies where possible.
5. Consider iLUC and related issues appropriately by standardisation
There is international recognition that the production of bio-based products instead of fossil-based ones can reduce greenhouse gas emissions and contribute to the adaptation to climatic change. However, as bio-based materials are ultimately obtained from land or sea, additional effects require consideration. These effects can moderate environmental performances and the original purpose of sustainability. iLUC has been defined as an unintentional, negative, displacement effect of commodities in the primary sector such as agriculture causing additional land use changes [48
Screenings and analysis of documents in the Perinorm database showed that iLUC represents a gap on the level of international standardisation. Likewise, experts, for example from the former ISO/PC 248, highlighted the need for action in this regard. The Dutch standard NTA 8080-1:2015 considers low iLUC risk (see also Section 3.2.4
). The requirements of this standard are also used for certification based on the standard NCS 8080:2017 and the Better Biomass certification scheme. Nevertheless, NTA 8080:1 describes specific limitations, for example, concerning new understandings and new issues such as “cascading ILUC” and “carbon debt” (see Appendix C
). Based on the input of the interview series, we suggest initiating activities to specify iLUC-related requirements on a European level. As mentioned earlier, CENT/TC 383 plans to make changes to the EN 16214-series on sustainability criteria for biomass for energy use to include the revised standards references to the 2015 iLUC Directive modifying both the Fuel Quality Directive (FQD) and the RED. Therefore, this work could be a starting point for standardisation activities for bio-based products, including the determination of assessment measures and thresholds.
6. Develop standards that provide guidance on social and economic LCA
According to expert opinion (see Appendix C
; Table A1
, Table A2
, Table A3
and Table A4
), social LCA (S-LCA) would bring the assessment of social sustainability of bio-based products on a par with environmental sustainability. Considering economic LCA by standardisation was also suggested. In addition to this, an interview of the interview series in the technical committees emphasised the need for a better link between EN 16751 and LCA standards, referring to existing LCA standards and the relation to future ones as well.
7. Create standards for the circular economy
The European Commission is aware of the importance of the Circular Economy and has developed, for example, the Circular Economy Action Plan [57
]. In line with expert suggestions (see Table A5
), work on standards in this area has to be regarded as a priority. Appropriate standards should be focused on design aspects of products, promoting products that are designed to be easily refurbished, remanufactured, reused, recycled, biodegraded safely. Specifying the need for action, an interviewee of the general expert interview series referred to the need for standardised methods to measure circularity characteristics. The British standard BS 8001:2017 Framework for implementing the principles of the circular economy in organizations might be used as a starting point in this regard.
8. Standardise sustainability criteria for bio-based polymers and lubricants
Most suggestions of the experts in both parts of our analysis referred to standardisation issues of bio-based products in general, not to specific product groups. Bio-based polymers and lubricants, for which product-specific standards were suggested, were an exemption in this regard. The bio-based polymer turnover was about €13 billion worldwide in 2016. Nevertheless, they represent only a share of 2% of the global polymer market and a significant increase in their production capacity is forecasted [58
]. Likewise, the market of bio-lubricants is growing significantly, from over 630 kilo tons in 2015 to expected 1115 kilo tons by 2024, growing at 6.9% Compound Annual Growth Rate (CAGR) from 2016 to 2024 [59
]. These quantities correspond a market size of $
2.92 (€2.47 (Exchange rate from 30 November 2017)) billion by 2024. The specific need for action regarding the development of sustainability criteria for both kinds of products was recognised by experts. As mentioned earlier, not only do criteria have to be developed, but assessment methods and thresholds as well.