Nov 29, 2016

ACA Comments on EPA’s EcoLabels and Standards Pilot Project

​(PAINT.ORGOn Nov. 1, ACA submitted comments to the U.S. Environmental Protection Agency (EPA) on the agency's pilot project to assess ecolabels and standards. EPA's proposed Draft Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement seeks to establish a framework to evaluate non-governmental environmental standards and ecolabels — and consequently, environmentally preferable products meeting these standards — for use in federal procurement. ACA serves on the pilot project's Paint and Coatings Panel.

The U.S. federal government is the largest purchaser in the world, and EPA has developed guidelines to help agencies in the federal government select environmental performance standards and ecolabels for their use. EPA is testing the guidance starting with three product category types: paint and coatings, flooring, and furniture. EPA has assembled a panel of stakeholders, including ACA and coating manufacturers, to evaluate the agency's guidance before it is finalized for use by other federal agencies.

EPA's goal is to create a transparent, fair, and consistent approach to selecting environmental performance standards and ecolabels to support the agency's mission and federal sustainable acquisition mandates.

EPA's pilot assessment criteria were made final in March 2016.  EPA piloted the criteria by seeking eco labels to volunteer to be assessed. ACA worked to ensure the guidelines provide manufacturers flexibility to accommodate the variety of approaches to and types of standards and ecolabels that exist in the marketplace today.

ACA understands the importance and necessity for the EPA to review existing ecolabels in the marketplace to make appropriate recommendations to guide federal purchasing.  However, ACA and its industry are concerned that major changes were made to the guidance document after the public comment period closed and without participation and feedback from the interested and impacted participants on the paint panel.  While the results of the pilot indicate that many Standards Development Organizations (SDOs) could not comply with certain criteria, it was understood that those criteria would signal the SDO community to improve their standards in the future. Instead, it appears that where the SDOs were unable to achieve critical criteria, such as open, transparent stakeholder involvement in standard development, the bar has been lowered to allow for closed door, arbitrary standard development.

In its comments, ACA made a series of recommendations to EPA, including urging the use of Voluntary Consensus Standards (VCS) for government purchasing, rather than amending the assessment criteria. ACA will continue to monitor the final stages of the pilot process and will remain engaged.

The impacts of EPA's pilot project could be significant since the results will inform the final guidance and determine what ecolabels and certification programs are deemed acceptable for use by federal government agencies for their purchasing.