56. One aspect of Integrated Product Policy which gave rise to some concern amongst witnesses was the use of 'life-cycle analysis' (LCA). The consultation paper Consumer Products and the Environment says, "The Government believes that environmental policies about products should be taken on the basis of sound science."[92] We agree. However, as the consultation paper goes on to point out, "this principle is rarely as straightforward as it sounds in the case of products."[93] LCA is perhaps the most thorough and scientific way of assessing where the most serious environmental impacts of a product occur, and therefore what measures should be taken to address them. However, it is important that the effort put into such assessment is proportional to the gains for the environment which can be made as a result. Sainsbury's gave us the example of the application they had made of formal life-cycle analysis to fresh and long-life milk packaging. This, they said, was "a very cumbersome, time consuming and expensive tool for decision making. In retrospect the final recommendations could have been identified—in rough terms—from an analysis of the summary data as available at the start of the project."[94]

57. It is therefore important that LCA be used with common sense. Dr Berkhout of SPRU said, "we would stress much less the scientific precision of the analysis of the environmental impacts and resource use of product systems than the formulation of a process by which some form of analysis is provided. Sometimes that can be as simple as a back-of-the-envelope calculation."[95] Similarly, Sainsbury's concluded that 'life-cycle thinking' was a more cost and time-effective approach than full life-cycle analysis.[96] Scientific analysis is important in assessing priorities for action: as Dr Berkhout told us, "The question facing policy-makers and producers is: what is the alternative? The alternative is prejudice. Clearly, one will make wrong decisions if one always accepts common wisdoms about the environmental impacts of different product systems. One needs science and a rigorous framework to try to understand the environmental impact of behaviour through the consumption of products."[97] However, it is our conclusion that life-cycle analysis should be used with an understanding that it is only a means to an end: that end being the identification of the priorities for action towards more sustainable patterns of consumption. As such, it may be appropriate to use simplified versions of the approach for products where the environmental characteristics or implications are clear-cut.

58. As part of the effort to educate consumers towards more sustainable patterns of consumption and as a safeguard on their accuracy, we recommend that, wherever possible, details of life-cycle assessments be made publicly available. This will help to make consumers more aware of the effect of the products they buy on the environment, will open such analyses to debate and scrutiny and should help to disseminate best practice.

59. A final point about product policy is that moving towards 'sustainable patterns of consumption' means taking account not just of environmental issues, but also of social and ethical ones. In this context we welcome the recent report of the Trade and Industry Committee on Ethical Trading. The Body Shop noted that "in the context of the EU ecolabel, the various expert groups and the competent bodies singularly failed to develop an LCA methodology which would adequately reflect societal values in the process of developing label criteria".[98] B&Q said, "We do not have confidence in 'life-cycle assessment'. It places too much emphasis on energy and aspects of the product's life-cycle which can be measured numerically. You cannot measure child labour, but it is the key issue with rugs."[99] We commend the inclusion of a note on 'social and ethical dimensions' in the Government's consultation paper on consumer products and the environment. We further hope that these issues will be directly addressed within the context of policies on consumer products.

93   Ibid Back

94   Ev p58 Back

95   Q38 Back

96   Ev p58 Back

97   Q39 Back

98   Ev p8 Back

99   Ev p21 Back