Communicating sustainability properly: the importance of type 1, 2 and 3 environmental labels

Communicating sustainability is a sensitive topic for companies in the fashion industry. 

Our Report Fashion and Sustainability 2022 shows that, although 99% of fashion companies are concerned with sustainability, the number of companies that overstate their sustainability awareness has increased in the last year. In particular, 44.8% of companies that are at a basic level of sustainability overstate their practices, thus exposing themselves to the risk of greenwashing.

This data is further supported by the Synthetics Anonymous Report conducted by the Changing Markets Foundation, which states that 59% of claims made by European and British fashion companies are misleading or unfounded. 

To solve this problem, the European Commission has launched a number of initiatives to combat greenwashing, such as the Green Claim Initiative and the Sustainable Product Initiative. 

Alongside institutional regulations, the International Organisation for Standardisation (ISO) has tried to solve the problem of greenwashing by standardising the communication of the environmental sustainability of products through the development of three environmental labels, which allow products to be categorised according to their environmental characteristics.

ISO standards: development and definition of environmental labels

The aforementioned Green Claim Initiative, launched by the European Commission, stipulated that generic environmental claims will only be authorised if they are validated by a standardised methodology that guarantees reliable, verifiable and comparable data throughout the European Union.

In this sense, the ISO standards for environmental labelling provide clear definitions and guidelines shared by the European Union, providing clarity with respect to the multitude of environmental claims circulating in the market.

Environmental labels refer to the ISO 14020:2022 standard and are divided into three types:

• Type I environmental labels (ISO 14024): eco-labelling of products for which there are clearly defined criteria (such as the Ecolabel).
• Type II environmental self-declaration (ISO 14021): eco-label for products or services for which there are no defined criteria. This is a label self-declared by manufacturers, importers or distributors.
• Type III Environmental Declarations (ISO 14025): labels that contain quantification of environmental impacts based on LCA calculations of the entire life cycle of the product. 

Depending on the type of label, obtaining one of these environmental labels may require mandatory verification by third-party bodies.

An example of Type I labelling: the Ecolabel

ISO 14024 defines Type I environmental labelling as a "voluntary scheme that officially identifies and certifies that certain products or services, throughout their life cycle, have a reduced impact on the environment". Eco-labels falling into this category must therefore be awarded by an independent third party, acting as a Certification Body, and be based on scientific criteria for analysing the impacts of the product's entire life cycle. 

This standard is recognised globally and has been adopted by the Global Ecolabelling Network (GEN) as the reference for environmental labelling.

The type I environmental labelling developed by the European Union is the EU Ecolabel, established in 1992 and now recognised globally. 

The Ecolabel certifies products with a low environmental impact and is independently verified by third parties who attest that the products meet the standards of the label.

To obtain the Ecolabel, products must meet certain environmental and performance standards from raw material extraction to end-of-life management.

Ecolabel criteria for textile products

The European Commission has published a technical handbook for textile products in which the ecological criteria for the award of the Ecolabel to textile products and their sub-categories are set out. The validity of these criteria has been confirmed until 2025. 

Within the document they are defined as 'textile products':

• textile clothing and accessories
• interior textiles
• textile fibres, yarns, cloth and knitted panels
• non-textile items (zips, buttons and other accessories as well as membranes, coatings and laminates)
• cleaning products

While there are 28 criteria to be met in order to obtain the Ecolabel, they are divided into five groups. These verification criteria cover: 

• Textile fibres: assessment and verification of the complete composition of the product to demonstrate compliance with the standard of the textile fibres used. The criteria to be met also concern the percentage of recycled fabric used. 
• Components and accessories: evaluation and verification of the materials used. This group includes metal and plastic upholstery, covers and accessories.
• Chemical substances and processes: the substances, formulas and production technologies used to manufacture and impart specific qualities and functions to the product during spinning, pre-treatment, dyeing, printing and finishing, as well as to treat air emissions and wastewater
• Suitability for use: the performance of the product is determined through specific tests to verify colourfastness under certain conditions, resistance to pilling, abrasion, water repellency durability, ease of maintenance and fire resistance
• Corporate social responsibility: this applies to the production stages of cutting, making up and finishing textile products. Consequently, applicants are required to ensure compliance with the fundamental principles and rights enshrined in the ILO Core Labour Standards, the UN Global Compact initiative and the OECD Guiding Principles.

These criteria aim to identify products with the lowest possible environmental impact throughout their life cycle.

Subsequently, the EU also defined specific Ecolabel criteria for footwear.

There are 10 criteria for awarding the label: 

• Origin of hides, cotton, wood and cork as well as man-made cellulose fibres: e.g. in the case of man-made cellulose fibres (including viscose, modal and lyocell), at least 25.0% of the non-recycled pulp fibres must be produced from wood from forests managed according to the principles of sustainable forest management as defined by the FAO. The remainder of the non-recycled pulp fibres shall be made from pulp from legally managed crops and forests
• Water consumption reduction and restrictions for hide tanning: water consumption expressed as the average annual volume of water consumed per tonne of raw hides and skins cannot exceed 28 m3/t for large hides and skins, 35 m3/t for vegetable tanning, etc.
• Emissions to water from leather, textile and rubber production: e.g. the COD (Chemical Oxygen Demand) value in wastewater from leather tanning sites discharged to surface waters after treatment (on-site or off-site), may not exceed 200.0 mg/l
• Volatile organic compounds (VOCs): unless otherwise specified, the total use of VOCs in final footwear production shall not exceed, on average, 18.0g VOC/pair
• Hazardous substances in the product and footwear components: substances and mixtures meeting the criteria for classification according to Article 57 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council as Substances of Very High Concern (SVHC) as well as substances or mixtures meeting the criteria for classification, labelling and packaging (CLP) according to Regulation (EC) No 1272/2008 of the European Parliament and of the Council are restricted
• List of substances with restricted use: e.g. rosin is not used as an ingredient in printing inks, varnishes or adhesives
• Parameters contributing to durability: e.g. upper and sole resistance to bending, tearing, etc.
• Corporate social responsibility regarding employees' work: compliance with the principles of the International Labour Organisation (ILO) and the UN Global Compact (second pillar), the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises
• Packaging: e.g. the cardboard and paper used in the final packaging of footwear is made of 100% recycled material
• Information on the packaging: e.g. cleaning and care instructions for each product

Type II environmental labels: environmental self-declarations

ISO 14021 defines the requirements for type II environmental labels, also known as environmental self-declarations. These labels provide product information based on declarations by manufacturers or retailers, without being subject to third-party verification. 

The regulation provides a list of general requirements for the use of environmental terms and includes guidelines for the use, positioning, symbol size and graphics of labels to ensure that they are non-misleading, verifiable and specific.

Commonly used terms in Type II environmental labelling are: 

• Compostable 
• Biodegradable 
• Designed for disassembly 
• Extended life product 
• Energy recovered 
• Recyclable 
• Recycled content 
• Reduced energy consumption 
• Reduced resource use 
• Reduced water consumption 
• Reusable and refillable 
• Reduced waste

Type III labels: Environmental Product Declaration and LCA analysis

Type III environmental labels (ISO 14025), or Environmental Product Declarations, allow for the transparent reporting of objective, comparable and third-party verified data on the environmental performance of products and services based on a Life Cycle Assessment study.

According to ISO 14040:2006, the LCA methodology is defined as an environmental management technique to identify and assess the potential environmental impacts of a product, process or service during its entire life cycle, from raw material extraction to end-of-life management, evaluating different impact categories such as climate change, acidification, water eutrophication, photochemical smog formation, stratospheric ozone depletion, etc.

Environmental product declarations are regulated by two ISO standards:

• ISO 14025, Environmental labels and declarations - Type III environmental declarations - Principles and procedures: sets out the necessary procedures for developing the data and the requirements for obtaining the label. These requirements include the obligation of third-party verification of data. 
• ISO/TS 14027, Environmental labels and declarations - Development of product category rules: establishes guidelines for the development of product category rules that can be used globally. This standard contains rules for conducting the LCA study and the EPD itself.

In order to facilitate the comparison of the environmental impacts of the same product or service, it is necessary to establish product category rules (PCRs), i.e. documents that define the principles and requirements for writing EPDs for a specific product/service category.

Consequently, in order to facilitate the communication of the results achieved, EPDs that are based on the same product category rules (PCRs) are comparable with each other.

How Type 1, Type 2 and Type 3 environmental labels differ

Having examined the different types of environmental labels, we can state that the main differences between them concern the purposes, recipients and verification of the label. 

In particular, type I environmental labels have a selective purpose and are regulated by criteria recognised by the European Union (such as the Ecolabel), while type II environmental labels have an informative purpose and do not necessarily have to be verified by third parties. Type III labels, on the other hand, have a comparative purpose and are based on objective, quantifiable data, thus enabling production processes to be optimised and costs to be reduced for companies. 

A further difference lies in the independent verification of the labels. For type I and III environmental labels, third-party verification is in fact mandatory, while for type II environmental labels it is not. 

Finally, Type I labels are aimed at both consumers and businesses, Type II labels mainly at consumers and Type III labels mainly at businesses.

All in all, all three types of environmental labels represent a valuable support for creating corporate policies that meet international standards, increasing corporate transparency and basing one's sustainability communication on shared norms.

Conclusions

Most fashion companies run the risk of greenwashing due to incorrect or misleading communication about the sustainability of their products. 

The adoption of type I, II and III environmental labels, developed on the basis of ISO 14020:2022, can be a useful tool to clarify the environmental performance of products in the market. 

In particular, Type I and Type III environmental labels enable companies to communicate objective and verifiable data on their products by complying with European standards and validating the data through life cycle analysis (LCA) studies. 

Cikis supports your company in making an objective and comparable assessment of the environmental impact of products through LCA and provides the basis for communicating environmental performance in a fair and verifiable manner.