Ecolabel Final Report
Ecolabel Final Report
in India
January 2020
Contents
List of figures                                                         3
List of tables                                                          4
Glossary                                                                5
Executive Summary                                                       6
1.0 Introduction to Ecolabeling                                        7
2.0 Overview of Indian Market                                          12
3.0 Ecolabeling Program Feasibility                                    20
4.0 Ecolabeling Approach for Cooling Appliances                        24
5.0 Recommendations and Conclusion                                     27
Appendix A: Study Approach and Methodology                             29
Appendix B: Existing Global Ecolabeling Labels and Standards           31
Appendix C: Summaries of Stakeholder Consultations                     40
Appendix D: Additional Information – Life Cycle Assessment (LCA) for   42
Air Conditioners
Appendix E: List of Products Certified Under Ecomark                   44
List of Figures
AC         Air Conditioner
BEE        Bureau of Energy Efficiency
CFC        Chlorofluorocarbons
CO2        Carbon Dioxide
EEB        European Environmental Bureau
EU         European union
GECA       Good Environmental Choice Australia
GHG        Green House Gas
HCFC Hydrochlorofluorocarbon
HFC        Hydrofluorocarbons
ISHRAE     Indian Society of Heating, Refrigerating & Air-conditioning Engineer
LCA        Life Cycle Assessment
LCCP       Life Cycle Climate Performance
Ecolabeling is a method of environmental performance certification and labeling that is practiced around the world.
An ecolabel identifies products or services proven environmentally preferable overall, within a specific product or
service category.1 It measures the total environmental impact of a material or product, and assesses the
environmental performance of the product or material within its specific product category 2. It follows the life cycle
methodology; it measures the environmental footprint of the product through its life cycle.
Ecolabeling effectively identifies and establishes markets for green and efficient products, and fulfills three primary
objectives: environmental protection, encouragement of innovation in the environmental and efficiency sector, and
consumer engagement. Ecolabeling programs and schemes are typically backed by national and international
governmental agencies, and the primary stakeholders of any ecolabel are the government, industrial associations,
consumers, scientific agencies, and not-for-profit organizations.
Ecolabels have, historically, aimed at identifying and promoting products that have a reduced environmental footprint
as compared to other similar products. They encourage a move towards eco-friendly consumption patterns, and
provide incentives to governments, manufacturing entities, and consumer organizations to adopt sustainable best
practices.
Types of Ecolabel
Currently, there are three broad types of environmental/ecolabels that exist, as described below:
Type 1 – A voluntary program that grants a license after a thorough analysis of the overall environmental performance
of the product under consideration. This type is voluntary, multiple-criteria based, third party assessed program, and
awards a license, which authorizes the use of environmental labels on products indicating overall environmental
preference for a product within a product category based on life cycle considerations.
Type 2 – This involves self-declaration forms, which cover a wide variety of environmental criteria
Type 3 – Voluntary programs that provide quantified environmental data of a product, under pre-set categories of
parameters set by a qualified third party and based on life cycle assessment, and verified by that or another qualified
third party.
Ecolabeling Terminology
The key words in formulating an ecolabeling program include sustainability, responsibility, and ethical purchasing
behavior. These can be ensured by instituting verification processes, which involve an ecolabel certification. A few
relevant elements include the following:
Sustainable Production: Ecolabeling aims at developing environmentally-conscious design and manufacturing
processes that will not jeopardize the ability of future generations to benefit from the full range of available natural
resources.
Responsibly-managed: This is an important step to promoting sustainability using ecolabels. It involves an obligation
on the part of the certifying parties to minimize or eliminate the environmental footprint of a particular product by
incorporating actions that will contribute to maintain triple-bottom line sustainability.
Responsible Purchasing Behavior: Ecolabels and certified parties must make attempts to define and apply ethical
sourcing policies. They must attempt to raise awareness about resource usage and engagement with activities
designed to promote environmental conservation, which will trigger sustainable purchases.
Performance Framework: Key elements of an ecolabeling program will be assessed for life cycle sustainability, and
these assessments will form part of a performance matrix that provides specific qualitative and quantitative
characteristics of a particular product. The robustness of a performance network can be reinforced through expert
development, public consultation, peer review, and ongoing research and development.
Figure 2: Process of Customer Choice on Purchasing Environmentally Friendly Products (Bui, 2005)
A growing global concern for environmental protection by various governments and businesses led to a growth in
sustainable consumerism, which pointed toward the need for more dissemination of environmental performance
knowledge among the product manufacturers and retailers. Potential threats to the environment, arising as a result
of ozone depletion, urban waste generation, and pollution, have pushed for increase in the number of ecolabeling
schemes around the world.
3   “Three Steps to a Sustainable Economy”; Eckart Wintzen; May 2012; The Solutions Journal
The first Ecolabeling program, called Blue Angel, was instituted in Germany in 19784. The Blue Angel label measures
the environmental impact of a product by calculating the fossil fuel consumption, greenhouse gas
emissions, and other resource depletion. This label attempted at assessing the technological and design
developments for several product groups, and an above average performance rating was required to award the label.
A plethora of eco and environmental labels were thereafter introduced within several developed and developing
countries. In a typical Ecolabeling program, product categories and Ecolabeling criteria are determined by an
independent, third party organization, with assistance from one or more technical advisory groups.
Currently, the most prominent international ecolabel is the European Eco-Label Scheme. This scheme serves 135
companies, and has awarded labels to 21 product groups, ranging from paints, detergents, and refrigerator, to tourist
accommodations.5 The label is extremely popular among industrial associations and consumers, and is expanding to
include a wider range of products and services.
All ecolabels currently being implemented do not focus on a common impact parameter. On the contrary, there exist
several types and categories of labels that place an emphasis on specific categories. However, all ecolabels adhere
to a set of guiding principles to ensure credibility and effectiveness – these principles stress on holistic performance,
compliance with existing legislations, a sound scientific and engineering base, exceptional leadership, credibility,
attainability, and measurability, independence, and flexibility.
Figure 3: A snapshot of a few existing national and international ecolabels6
Many existing labels typically focus on one particular impact category (for example, air quality, water consumption,
energy consumption, etc.) and include a single sector (for example, appliances, tourism, building products, textiles,
etc.).
       Governmental announcements
       Newspapers
       Television
       Information facilities
       Publications/technical journals
       Conferences/public gatherings
       Internet
       Product labels play an important role in consumers’ decision making for product purchase;
       The vast majority of population believes that an ecolabeled product complies with all required environmental
        regulations;
       A rating system similar to BEE’s star labeling program is preferred by consumers, so as to accurately gauge
        the level of environmental performance and efficiency;
       Integrating the requirements of an ecolabel with existing local and international environmental regulations is
        preferred;
       Environmental management systems are a useful feature within manufacturing facilities;
       Consumers view a product with visible environmental aspects more positively than others; and
       Most consumers agree that an ecolabel for cooling appliances is useful, and they would prefer buying
        ecolabeled products.
The review also demonstrates that the following are the ideal characteristics of an ecolabel:
       Is a voluntary program;
       Connects to existing environmental regulations and laws;
       Incorporates within existing experiences, networks, and structures;
       Takes into account local characteristics;
       Does not discriminate against smaller manufacturing facilities and enterprises;
       Encourages periodic environmental performance monitoring;
       Focuses on widespread dissemination of its criteria, increases awareness of the program among the public;
        and
       Incorporates social equity.
02 Overview of Indian Market
The introduction of ecolabeling schemes and standards in several countries around the world has led to a growth in
green consumerism. However, it has been observed that several of these schemes also possess a string of
drawbacks and potential areas of improvement. Developing countries, in particular, have initiated discussions on the
impact of these schemes and standards on various products’ market accesses – the primary concern behind the
institution of such schemes is that these could add an additional layer of constraints, which could, in turn, detract the
product(s) or manufacturers from entering regional and global markets. It has been projected that ecolabeling
programs could attract capital investment and joint ventures in developing nations.
Ecolabeling is seen as an entryway into premium markets: for manufacturers willing to adhere to high environmental
standards, such programs present a valuable opportunity to differentiate themselves from other manufacturers, and
maintain a competitive market share. The uptake and growth of ecolabeled products will foster the growth of new
markets for such eco-friendly products, and this will, in turn, attract investors, and bolster partnerships between
nations to develop mechanisms to adhere to high environmental standards.
7   “Tracking the growth of India’s middle class”; Beinhocker et. al.; The McKinsey Quarterly (2007-3)
8   “An Overview of Eco-Friendly Products”; Shivaji University, Kolhapur
Figure 4: Appliance Demand by Sector (Ernst and Young, 2015)
                                         Consumer Electronics
                                         Electronic Components
                                         Industrial Electronics
                                         Computer Hardware
                                         Communication and Broadcast Equipment
                                         Strategic Electronics
The market for energy efficient products is expected to gain significant ground, and more stringent energy efficiency
and sustainability norms are expected to be instituted and supported by the Government of India. The energy-efficient
AC market as a whole is expected to constitute 7-8% of the total AC market by 2020.9
Companies and industry associations are formulating innovative pricing mechanisms and payment methods, such as
incentives and EMIs, to encourage widespread uptake of energy efficient cooling appliances. This is expected to be
accelerated with the use of better technology, as well as on the willingness of manufacturers to waive installation
charges and other miscellaneous expenses on the purchase of a high-performing cooling appliance.
According to research by Indian Society of Heating, Refrigerating & Air-conditioning Engineer (ISHRAE)11, Indian
consumers are increasingly opting for energy efficient products, and products with a lower environmental footprint.
The Bureau of Energy Efficiency (BEE)’s Star Labeling program has increasingly gained in popularity over the years,
and ISHRAE states that there has been a shift in consumer preference from one and two-star models to three and
four-star models.
Owing to a radical shift in Indian consumers’ preferences, and the increasing focus on energy efficiency and
sustainability, there exists intense competition among AC manufacturers and retailers to draw up competitive pricing
strategies while maintaining high levels of energy and environmental efficiencies.12
9 “Study on Indian Electronics and Consumer Durables Segment (AC, Refrigerators, Washing Machines, TVs); Ernst and Young; April 2015
10Business Standard – “Consumers switch to inverter ACs as energy efficiency gains ground”; September 2013
11 ISHRAE – Air Conditioner Market in India; September 2015
12 Economic Times – “LG moves towards high end, energy-efficient ACs”; January 6, 2017
Existing Labeling Programs in India
The Government of India has made considerable efforts to promote the uptake of environmentally-friendly and
sustainable products and services. One outcome of these efforts was the Ecomark labeling program, which has been
described in detail in the following pages.
Additionally, a few Indian and international labels related to energy and/or environment currently in use are detailed
below.13
Table 1: Labels Currently Used in India
 Better                                                           Global
 Cotton                                                           Organic
 Initiative                                                       Textile
 (Australia,                                                      Standards
 China, India,                                                    (UK,     India,
 Pakistan,                                                        Spain,
 Turkey, USA)                                                     Germany,
                                                                  France)
Concept
Ecomark is based on a complete life cycle assessment and analysis, and adopts a cradle-to-grave approach. The
label measures the environmental footprint of a product right from the raw material extraction stage, through the
manufacturing and consumption stages, and the disposal stage. The criteria for eco-evaluation of the product(s)
under consideration depend on several other product-specific aspects; for example, all products certified under this
program must have significant potential to mitigate pollution, must comprise a considerable percentage of recycled
content, and minimize non-renewable resource consumption, among others.
The main objectives behind the institution of the Ecomark labeling program were to encourage the consumption of
environmentally-friendly products, educate manufacturers and consumers about the environmental impacts of several
product types, provide incentives to mitigate the harmful effects of environmental degradation, and improve the overall
quality of the environment and ensure long-term sustainability.14
14   Ministry of Environment and Forests; Department of Environment, Forests, and Wildlife; Resolution dated 20 February 1991
The Ecomark labeling program for a product ensures that:
(a) It has substantially less potential for pollution than other comparable products in production, usage and disposal.
(b) It is recycled, recyclable, made from recycled products or biodegradable, where comparable products are not.
(c) It makes significant contribution to saving non-renewable resources, including non-renewable energy sources and
natural resources, compared with similar products.
(d) The product contributes to a reduction of the adverse primary criteria which has the highest environmental impact
associated with the use of the product, and which will be specifically set for each of the product categories.
The program logo is an earthen pot, which symbolizes the use of renewable resources and the protection of
biodiversity.15 The logo attempts at epitomizing environmental conservation, and promotes environmental awareness
among the public.
The label measures the following to determine the environmental performance of a product, and varies these
parameters based on the product type:
     (a) Production process including source of raw material;
     (b) Natural resource consumption;
     (c) Likely impact on the environment;
     (d) Energy conservation in the production of the product;
     (e) Effect & extent of waste arising from the production process;
     (f) Disposal of the product and its container;
     (g) Utilization of "Waste" and recycled materials;
     (h) Suitability for recycling or packaging;
     (i) Biodegradability
        Assessment of the product for Ecomark, certification of the product for award of Ecomark.
        Renewal, suspension and cancellation of the license.
        Products certified as eligible for the Ecomark shall also carry the ISI Mark (except for leather) for quality,
         safety and performance of the product and shall be licensed to carry the Ecomark for a prescribed time period
         after which it shall be reassessed.
15N S Raman, A P Singh, and U P Waghe; “Ecomark Scheme in India”; International Journal of Pharma Medicine and Biological Sciences;
October 2012
          Undertaking inspections and taking samples for analysis of any material or substance in relation to which the
           BIS - Ecomark has been used as may be necessary for proper implementation of Ecomark. For this purpose,
           the Standard Mark of Bureau would be a single mark having a combination of the ISI Mark and the ECO Logo
Stakeholder Consultations
In order to assess the feasibility of an ecolabeling program in India, strategic consultations were done with key
agencies involved in standards, labeling, and environmental policies in the country. These include the Bureau of
Indian Standards (BIS), Bureau of Energy Efficiency (BEE), Ministry of Environment, Forest, and Climate Change
(MOEFCC), and United Nations Environment Program (UNEP). The purpose of the consultation was to introduce the
concept of ecolabeling, understand the barriers and explore opportunities for integrating ecolabeling with the current
ongoing programs, if possible. A summary of these discussions is given below.
Bureau of Indian Standards (BIS) is the nodal agency for implementing the existing ‘Ecomark’ program. Multiple
consultations were held with the BIS officials to get a feedback on the experience of the Ecomark program and to
seek opinion on the feasibility of the proposed comprehensive Ecolabeling concept. These consultations were
positive, and the officials at the BIS were supportive of the concept. They endorsed the proposed approach of
expanding the scope of the existing Ecomark program for greater coverage and uptake. BIS was also keen to play
the role of the nodal technical, standard setting, and testing agency for the expanded Ecolabeling program.
Further, BIS was open to idea of initiating the program with integrating ecolabeling criteria within the existing standard
for air-conditioners and other cooling appliances. The room air conditioner standard is under revision and it would
be possible to introduce additional criteria at this stage. Some of the key environmental criteria for cooling appliances
and equipment are global warming potential, human toxicity, emissions, and energy consumption.
A final presentation was made to the BIS staff at a knowledge-sharing workshop. The title of the presentation was
"ECO labeling in India and its application on Room Air-conditioners". Participants in the workshop endorsed the
concept and gave valuable feedback on making the program more effective.
Ministry of Environment, Forest, and Climate Change (MoEFCC) is the nodal ministry with the mandate of
implementing the current Ecomark scheme. A presentation on the concept of ecolabeling and its benefits, focusing
on cooling appliances, was delivered to MoEFCC officials.. The Ministry was interested and supportive of the concept,
and also approved the idea of building on the existing Ecomark program – where MoEFCC can create a broader
implementation framework. MoEFCC also supported the idea of BIS as the institution responsible for the roll-out and
overall administration. A follow up meeting was held with MoEFCC to discuss potential challenges, and to draft a
detailed action plan for the implementation of Ecolabeling.
As result of this feasibility study and extensive support generated, MoEFCC agreed to the concept of Ecolabeling as
being the key to a consumer centric approach for efficient and sustainable cooling for India. Subsequent discussions
and follow up resulted in MoEFCC accepting to include Ecolabeling as a key recommendation under the India
Cooling Action Plan which paves the way forward for further work and development of action plan.
India Cooling Action Plan: Short-term Recommendations
    1. Implement Eco-labeling programme for cooling appliances in India The environmental footprint of cooling
       equipment in terms of GWP (or ODP), GHG emissions, should be factored in combination with safety,
       performance, and energy efficiency, under a single eco/environmental label.
    2. Add cooling appliances under MoEF&CC, Government of India’s ‘Ecomark’ scheme on labeling of
       environment friendly products.
Figure 6: Excerpt from India Cooling Action Plan - Recommendations & Way Forward
United Nations Environment Program (UNEP): As a key partner to the Government of India, UNEP has been
supporting implementation of sustainable public procurement aimed at advancing sustainable consumption and
production. Discussions with UNEP strengthened the feasibility concept and approach for India and they also stressed
the importance of this concept for establishing transparency and compliance for environmental benefits. They
suggested that the proposed criteria also focus on climate change mitigation and appliance disposal mechanisms.
Bureau of Energy Efficiency (BEE): Discussions were held with BEE and although BEE is overall supportive of
Ecolabeling, but they see their mandate limited to energy related criteria only. Therefore BEE is of the opinion that
they cannot directly add environmental criteria to the energy label, unless a mandate is given by the Government to
do so. Overall, BEE is willing to support MoEFCC and BIS to propagate it.
Industry, Experts and other stakeholders: Discussions and deliberations at the stakeholder meetings indicate that
interest and participation among industry groups and product manufacturers were varied. Many manufacturers,
retailers and suppliers would potentially agree to ecolabeling for one or more of the following reasons:
    1.   To adhere to corporate social responsibility policy
    2.   To increase customer interest/satisfaction
    3.   To improve brand image
    4.   To cater to demand for environmentally-friendly products among select customers
    5.   To better compete with other retailers
    6.   To increase sales
    7.   To improve supply-chain management
        Gradually introduce and set international standards as the norm to be followed by local products circulated
         both externally and internally;
        Create policies and regulations that enable manufacturers to maintain price competitiveness;
        Ensure harmonization with international environmental laws and standards.
Maximizing the Impact of the Proposed Ecolabel
The goals of the proposed ecolabeling criteria are to:
           Improve with respect to India’s international competitive position, by the creation of specific markets for
            sustainable cooling;
           Improve the overall quality image of India’s cooling appliances; and
           Improve the environmental performance of existing cooling appliance models.
Thus, the proposed ecolabeling criteria will serve as an effective response to India’s environmental concerns. The
program will also be considered as an effort to boost the country’s trade prospects with its progressive, western
counterparts.
The proposed criteria will entail multiple layers of environmental compliance, and will attempt at formulating a set of
criteria for all cooling appliance manufacturers. The higher levels of environmental compliance will compete with
internationally acclaimed ecolabels for cooling devices, such as the EU Ecolabel.
Products that are able to adhere to the higher compliance levels will receive international recognition, and will
consequently improve India’s standing in the global cooling market.
The ecolabeling criteria will also align itself with the goals of India’s National Cooling Action Plan, which aims at a
market transformation to include more sustainable cooling equipment.
                                                                 Private Sector
                                                                  Purchasing
                                                                    Public
                                                                 Procurement
                                               Market Demand
                                                               Sufficient Demand
                    Good Future
                     Prospects
                                                                   Improved
                                                                   Consumer
                  Market Impact                                    Behaviour
                                                                     Lower
                                                               Certification Cost,
                    Substantial                                    Incentives
                   Adoption Rate
                                                               Tangible Benefits
04 Ecolabeling Approach for Cooling Appliances
Room air conditioning units with cooling capacity up to 7 kW make up more than 80% of sales in India 18. Experiencing
a growth of 10-15% annually, AC demand is projected to grow around 8 times by 2037-38 as compared to the 2017-
18 baseline19. Additionally, based on the anticipated demand for cooling equipment in the country, the cooperation of
the entire cooling industry in the uptake of the ecolabeling program will be valuable, following which, demand for
these products will continually show an upward trend.
A market transition to energy efficient and environment friendly air conditioners will not only accrue environmental
benefits, but also reduce consumer electricity costs, increase energy security, expand the manufacturing sector, and
create green jobs. Ecolabeling for air conditioners can be seen as a key to this transition strategy.
The approach to developing an ecolabeling program for air conditioners will be aligned with the broader framework
of an ecolabeling program/revised Ecomark scheme. Some of the key parameters for ecolabeling will include20 the
guidelines for implementation (code of conduct), inclusion within relevant certification schemes/policy frameworks,
relevant benchmarks for performance evaluation. The main steps for ecolabeling will include:
     1. Identifying categories of environmental impact to be factored in the labeling program;
     2. Quantifying environmental performance through life cycle assessment; and
     3. Establishing the maximum thresholds for each criteria for each product category
Figure 8: Ecolabeling Framework for Cooling Appliances
               Scheme                                                                  Geographic
                                         Sector               Issue Scope
               Format                                                                    Scope
                                           Other HVAC
                 Benchmarking                                         Quality                 Regional
                                            equipment
                                                                    Safety and
                     Label                                                                     Local
                                                                      Health
                   Consumer
                   guidance
Ecolabeling Criteria
Based on reviews of international environmental regulations and ecolabels, a set of potential criteria have been
identified. Some of these criteria can be mandatory for product, and the rest, voluntary, to be pursued at the discretion
of the certifying party.
     1. Management, Operations & Maintenance
                   i. Environmental Management System
                  ii. Human Resource Management
                 iii. Sustainable Operations & Maintenance
                 iv. Communication, Social Education, and Outreach
                  v. Facility Resource Monitoring
The scope of ecolabeling requirements can be expanded beyond environmental footprint – to include social equity,
quality and durability of products, and human health and safety.
Stakeholder Engagement
Stakeholder involvement is crucial for a successful ecolabeling program. These include government agencies,
manufacturers, industry professionals, retailers, industry associations, and consumers. The program approach,
design, performance objectives, challenges, and applicable benefits need to be discussed through multiple
consultations with each group.
Consumer Outreach
Increase consumer awareness and recognition for ecolabeled products for            influencing consumer purchasing
behaviors.
Consumer and Industry Incentives
Incentives for manufacturers, such as tax breaks, awards, or free recognition and publicity; consumer incentives such
as tax rebates, prizes, or price stability will greatly expand participation in the proposed ecolabeling program.
Ecolabeling criteria for cooling appliances in India is intended to provide information to consumers about the
environmental footprint of different products, and enable them to make sustainable choices. This program will serve
to provide incentives to reward manufacturers and retailers that adopt the required environmental criteria, and will
drive innovation and improvements in cooling appliance production. Furthermore, it will develop new markets and
increase market access to select products meeting ecolabeling criteria.
Supportive mechanisms and policy frameworks should be put into place to overcome or mitigate the effect of these
barriers, as detailed below.
    1. Creation of supportive policy and regulatory environments, which also include environmental performance
       targets;
    2. Creating a greater role for industry trade associations to encourage the sharing of information and data, and
       minimize the lack of awareness of newer, cutting-edge environmental technologies;
    3. Creating and managing a team of environmental specialists or analysts to monitor and evaluate
       industrial/manufacturing performance systems;
    4. Conducting training programs and capacity building activities for industry staff and managers to build
       technical capacity;
    5. Exploring financing options for the incorporation of state-of-the-art equipment within facilities; and
    6. Adequate marketing to increase exposure to ecolabeled products, and consequently increase demand for
       these products; and
    7. Governmental agencies, such as the MOEFCC and BIS, should initiate pilot projects on a select group of
       cooling products to demonstrate the value of life cycle management to the entire pool of Indian appliance
       manufacturers. Additionally, these agencies must also make available the required tools, trainings, and data
       for life cycle management, and this strategy should be integrated into governmental processes.
       Most of these ecolabels adopt a holistic approach to environmental performance assessment and include
        several environmental/ecological impact categories/parameters, such as energy use, climate change/global
        warming potential, carbon footprint, resource/fossil fuel consumption, quality, and toxicity;
       Several of these labels adopt a life cycle impact analysis methodology when awarding certifications, and
        focus on conducting a typical inventory analysis to conduct accurate calculations;
       Considering the exponential rise in usage of cooling devices among the residential and commercial sectors
        in India, the institution of an ecolabel for cooling devices in the country is imminent. Several ecolabels have
        already been instituted in countries such as the US, UK, Japan, and Korea, to emphasize on energy efficiency
        within cooling appliances. The proposed labeling program could be modeled based on these international
        ecolabels;
       It is feasible to introduce an Ecolabeling program for cooling devices in India. To successfully design and
        implement such a program, it is essential to institute a framework that will attract manufacturers, and facilitate
        ease of certification;
       Strategies for communication and public dissemination of the proposed ecolabel will have to be mapped out;
        and
       The Ecolabeling framework will have to be designed in a way to potentially include other sectors and product
        types in the future.
The characteristics of the proposed ecolabeling criteria will include the following:
       The proposed criteria will be partly voluntary, will intend to promote products with reduced environmental
        impact throughout their entire lifecycle, and will provide consumers with accurate, transparent, and
        scientifically-proven information on the environmental impact of products;
       Future amendments to the proposed ecolabeling criteria will be possible after gathering appropriate
        experience in administering the label;
          Amendments will be incorporated in compliance with the provisions of the administering organization of the
           proposed ecolabel;
          The proposed ecolabeling criteria will be based on the highest environmental standards and regulations
           currently operational in India, with the aim of achieving the best environmental performance for all products
           bearing the proposed ecolabel;
          The ecolabeling criteria will aim at reducing human toxicity due to hazardous substances;
          It is expected that environmental NGOs and consumer organizations will play an important role in the
           widespread uptake and marketing of the proposed ecolabeling criteria;
          The general public will be informed of the ecolabeling criteria and its policies through marketing campaigns
           and awareness programs;
          The ecolabeling criteria will inform consumers and industry associations of the environmental characteristics
           of all products covered by the program;
          Priority will be given to alternative, innovative compliance methodologies and technologies, as well as self-
           regulation. Self-regulation methods will be assessed by openness of participation, added value, quantifiable
           goals, representativeness, involvement of civil society, monitoring and reporting, and cost-effectiveness21;
           and
          The scope of the proposed ecolabeling criteria is subject to expansion to other product categories.
Instituting ecolabeling criteria specifically for cooling devices, within India’s Ecomark, is expected to achieve the
following benefits:
21   Directive 2009/125/EC of the European Parliament and of the Council; October 2009
Appendix A: Study - Approach and Methodology
Scope
The study involves a feasibility study for the introduction of an ecolabeling program for cooling appliances in India, its
key features, and methodology for development of a framework for implementation. This study includes the following:
    1. A thorough and comprehensive assessment of existing labeling program in India and internationally including
       existence of any Act, rules and regulations, and compare the measurement methodologies of each.
    2. A detailed literature review of reference documents which includes existing standards and regulations,
       academic studies on the environmental impacts of refrigeration and air conditioning devices etc. Formulate
       strategies to reduce the impact of these stages on the environment and the climate.
    3. A framework for integration of proposed ecolabeling criteria for cooling appliances into the existing Ecomark
       program.
    4. A feasibility of the integration of various existing metrics, such as the Life Cycle Climate Performance (LCCP)
       index, within the proposed label; the possibility of the integration of these mandates within existing policy
       frameworks.
Figure 9: Approach and Methodology
                                                                 Impact
                                             Review
                                                                 Categories
                                             Universe of
                                                                 Framework
                                             Criteria
                  • Formation of list of                                                 • Framework to
                    criteria to be adopted                                                 establish and roll-
                    within proposed                                                        out proposed
                    ecolabelling program                                                   ecolabelling
                                                                                           program
       Air Pollution: The environmental impact in this category will be measured by measuring the quantity of
        contaminants released by the product.
       Water Pollution: The environmental impact of the product in this category will be measured by quantifying
        the amount of water used and changes in water quality based on several quality indices (such as total
        suspended solids, pH value, alkalinity, and biological oxygen demand). This assessment will follow ISO
        14044 and ISO 14046.
       Energy Consumption: Energy consumption and efficiency will be measured as per the respective Indian or
        international standard.
       Global Warming Potential: This will measure the heat trapping capacity of the product and will be
        represented in carbon dioxide emitted, in kg or tonnes CO2 equivalent.
       Acidification: This phenomenon is caused by significant increase of CO 2 in the atmosphere, which results
        in an increase in oceanic CO2. This in turn leads to a decrease of the average pH value of the ocean surface.
        This phenomenon could be kept in check by monitoring a product’s CO 2 expulsion, and by conducting
        alkalinity tests on discharges released into water bodies.
       Ozone Layer Depletion: A product’s impact on this category can be measured and mitigated by prohibiting
        or phasing out the use of HCFCs and other ozone depleting chemicals, such as halons and synthetic
        halocarbons.
    Figure 10: Sample Eco-indicator diagram
Since the focus of the proposed ecolabeling criteria is cooling devices, an effort will be made to assess the footprints
of the HFC and HCFC refrigerants, as well as that of the relatively newer and more eco-friendly refrigerants, such as
HFC410A. The study will emphasize on strategies to reduce global warming and ozone depletion potentials, as well
as the discharge of industrial wastes. The program will be designed in such a way as to require appropriate clearances
confirming compliance with the mandates of the Water (Prevention and Control of Pollution) Act, Water (Prevention
and Control of Pollution) Cess Act, Air (Pollution and Control of Pollution) Act, and Noise Pollution (Control and
Regulation) Rules.
The study also lists out the several environmental impact categories that could be incorporated into the proposed
program. It advocates the use of an “Eco-indicator” diagram to calculate environmental performance of a product.
The specific environmental impact categories have been described in detail in later sections.
Appendix B: Existing Global Ecolabeling Labels and Standards
A comprehensive review of three major Ecolabeling programs around the world – the EU Ecolabel, Green Seal, and
Good Environmental Choice Australia – sheds light on the successes and failures of each program, and generates a
series of recommendations to facilitate the incorporation of an Ecolabeling program in India. An abbreviated list of
International ecolabels for cooling devices is provided below.
Table 3 A Few Existing Global and National Ecolabels
 BASF       ECO-           Brazil, Germany, USA         Cooling devices, building products, cleaning
 EFFICIENCY                                             products, cosmetics, electronics, energy,
                                                        forest products, healthcare, machinery
 ENERGY STAR               USA,   New        Zealand,   Cooling devices, building products, household
                           Canada                       appliances, electronics, machinery
The EU Ecolabel
BACKGROUND TO THE LABEL
       Instituted in 1992 and has been in operation for several years; has
        seen several significant changes and modifications to its
        environmental performance mandates.
       The European Commission currently manages the roll-out and
        implementation of this label, and the program is part of an overarching
        EU Action Plan on Sustainable Consumption and Production and
        Sustainable Industrial Policy.9
       This labeling program covers a wide variety of products and product
        types, and includes a comprehensive range of environmental
        performance assessment criteria. It includes personal care products,
        cleaning products, textiles, paints, electronic equipment, coverings,
        furniture, garden equipment, household appliances, lubricants, paper
        products, and ecotourism. Certain substances, such as UV varnishes and UV inks, are exempt from the
        requirements of this labeling program.
       It is a voluntary program that promotes environmental excellence among manufacturers, and provides a
        means of reducing environmental impact to consumers.
       Most prevalent in France, Italy, and Germany.
       Environmental criteria include recyclability, water emissions, air emissions, waste generation, and energy
        consumption.
       The total number of licenses awarded under this program has increased from 95 in 2001 to 1671 in 2012,
        and the number of companies registered under this program has increased from 83 in 2001 to approximately
        1000 in 2012.
       The direct benefits of using an EU Ecolabeled product include conservation of electricity and water, reduced
        pollution, materials savings, and reduced hazardous substance use.
       The indirect benefits of using this label include the establishment of a robust framework for future ecolabels,
        increased stakeholder awareness, and potential for the establishment of fiscal measures to promote green
        products.
       There currently exist discrepancies in performance measurement mechanisms of the products certified under
        this label.
       There is a dire need to modify existing environmental performance parameters to become more competitive.
       The other drawback of the program is that it includes a non-feasible set of environmental performance criteria
        that makes it difficult for several products and product types to meet those criteria.
       Furthermore, the program does not offer sufficient financial incentives to adhere to the mandates of this
        program, and there exists a current non-realization of the complete potential of the program.
Barriers to EU Ecolabel Implementation, Implemented Solutions
A joint study conducted by the European Environmental Bureau (EEB), The European Consumer Organization
(BEUC), and Association for the Coordination of Consumer Representation in Standardization (ANEC), identified
loopholes in the implementation of the EU Ecolabel, and suggested roundabout strategies for the same. A summary
of this study has been provided below:
Table 4 EU Ecolabel Roadblocks and Solutions
 PROBLEM                                               SOLUTION
 Initial cost of adopting the ecolabel                 Improve sales, develop effective marketing
                                                       strategies, bolster demand for eco-friendly
                                                       products
 Too much documentation and red-                       Simplify     paperwork         by     integrating
 tape, documentation too complex                       documentation requirements with those
                                                       required by existing industrial standards
 Lack of recognition by stakeholders                   Improve communication to stakeholders
 and public institutions, difficulty of                through effective claims that correspond to
 communication to stakeholders and                     societal expectations
 consumers
 Requirements do not address the Put into place a periodic review mechanism to
 most relevant environmental impacts keep up with technological advances
In the institution of an ecolabel for India, an attempt should be made to craft a realistic set of environmental
assessment criteria for different types of air conditioners, as well as for other energy-consuming cooling equipment.
A life cycle systems boundary must be set for each, and the scope of environmental performance monitoring must
be clearly defined. Furthermore, the introduction of financial incentives must be explored to encourage more
participation in the Ecolabeling scheme.
        Central cooling systems: Systems that are designed to provide cooling to the whole building, or a major
         chunk of a building. These systems typically incorporate distribution systems
        Space cooling systems: Systems that provide cooling to one or few rooms. These systems do not
         incorporate distribution systems.
Several additional types of cooling equipment (circulators, central AC units, room ACs, local mechanical ventilation)
are then listed out.
The second step to the development of criteria is to assess the types of fuels and energy sources used within these
systems. Global Warming Potential (GWP) is a key impact category in the development and successful roll-out of
Ecolabeling schemes for cooling devices in the EU. The several types of energy sources currently used include the
following: natural gas, liquid fuel, liquid biofuel, electricity, solid fuel, and solid biomass fuel. Error! Bookmark not defined.
The two steps involved in cooling a particular portion of a building are then taken into considerationError! Bookmark not
defined.
         :
In drafting environmental criteria, the approximate usage patterns of different cooling equipment are analyzed and
divided into the following categories.Error! Bookmark not defined.
       High primary energy consumption (with significant emissions) – equipment typically employed within
        industrial facilities
       Long operating times (up to 24 hours a day)
       Intermittent usage (up to 8 hours a day)
The uptake of these types of equipment with the three key types of sectors (domestic, tertiary, and industrial) are also
taken into account when making this distinction.
The ecolabels operating in the EU consider the following environmental impact categories when conducting an impact
assessment.Error! Bookmark not defined.
       Recyclability
       Global Warming Potential
       Life of Product
       Reparability
       Pollution
       Energy Consumption
Some labels also take into account third-country specifications (such as Minimum Energy Performance Standards –
Japan, and ENERGY STAR – United States), when developing criteria. The life cycle stages typically considered,
and the measurement parameters usually adopted, are given below.Error! Bookmark not defined.
Table 5: Life Cycle Stages and Measurement Parameters
The performance assessment methodology adopted by this program complies with the ISO 14040 series of
standards. Certifying products are required to comply with a rigorous set of environmental criteria, and adhere to a
periodic monitoring process and demonstrate continuous improvement.21
The labeling program follows the requirements set down by the U.S. Environmental Protection Agency to implement
transparency in third-party certificationError! Bookmark not defined.:
Additionally, several other operational aspects of the Green Seal program can be adopted for the proposed
Ecolabeling program in India. For example, Green Seal offers marketing services to interested manufacturers: it
assists in the development of a consumer outreach plan and sales strategies, aids in the certification of newer product
types, and provides advice on sustainable packaging techniques.Error! Bookmark not defined. Furthermore, a s
eparate standard to measure environmental innovation was recently introduced under the Green Seal umbrella – a
move that could be successfully instituted in the Indian context.
           Functional Performance
           Protection of Human Health and Environment
           Innovation – demonstrating that performance is equivalent or significantly better than other similar products
The result of this certification is that the concerned manufacturer can earn recognition as an industry leader, build a
brand for the innovative product or service, and consequently increase customer base.
Manufacturers of cooling equipment that are interested in certifying under GECA must first demonstrate compliance
with AS 1677 (Refrigerating Systems).
Relevant Criteria That Could Be Adopted Within the Indian Scenario
The GECA labeling program includes environmental, health, and ethical criteria to be met.
Environmental Criteria
       Ozone depletion potential must be zero
       Global warming potential must be less than 10
       Packaging must be easy to recycle, or should be subject to a take-back arrangement with the manufacturer
Health Criteria
       Packaging must not contain chlorinated or halogenated products
Ethical Criteria
       Demonstrate workplace safety, fair pay, equal opportunity
       Suitable information must be supplied to the public (such as Safety Data Sheets)
       All environmental claims must be independently verified
       Lawful conduct and environmental compliance must be enforced
A number of documents, including, but not limited to, permits, signed declarations, pay slips, documentation of
compliance with ISO 14021, all product advertising material, are required to be submitted for verification before final
certification.
Manufacturers dealing specifically with cooling equipment experience the following benefits post-certification with
GECA:
For India, the establishment of a standard to measure refrigerants’ sustainability will have to take into consideration
the global warming potential of the product(s) under question, as well as human toxicity, affordability, and resource
consumption.
Korea Ecolabel
BACKGROUND TO THE LABEL
The Korean Ecolabeling system was launched in 1992, and is an advanced environmental
labeling program that covers approximately 161 categories of products, including, but not
limited to, paper, photocopy machines, printers, paints, and cooling devices.
It is administered by the Korean Ministry of Environment’s Environmental Technology and Economy Division, and the
Korea Environmental Industry and Technology Institute (KEITI).24
This label can be classified as a Type 1 ecolabel, and follows the ISO 14024 framework. It facilitates the provision of
reliable information on eco-friendly products to consumers, and directions to companies to develop/manufacture and
sustain eco-friendly products.
The Korean Ecolabeling program covers the following product categories:
      KEITI elevates the brand image of certified products by offering special recognition and registration with
       governmental agencies. KEITI offers promotional services to certified products and manufacturers
    There are mandates in place to facilitate obligatory purchase of certified products by public institutions.
The other success factors of this label include the following. Error! Bookmark not defined.
        Mandatory governmental provisions to bolster the growth of a market for eco-friendly products
        Establishment of a monitoring, evaluation, and learning system for periodic upgradation of labeling clauses
         and ensuring sustained compliance with these clauses
LIMITATIONS AND SCOPE FOR IMPROVEMENT FOR THE LABEL
This label was also initiated in 1992, and targets products with high energy consumption. All products certified under
this program are required to indicate their “energy efficiency grade”, which quantifies their energy consumption and
energy saving potential.
This label covers the following appliances: refrigerators, freezers, ACs, washing machines, dish washers, dish driers,
hot and cold water dispensers, rice cookers, vacuum cleaners, electric fans, air cleaners, incandescent lamps,
fluorescent lamps, lamp ballasts, 3 phase electric motors, domestic gas boilers, electric cooling and heating
equipment, TVs, window sets, electric transformers, electric fan heaters, electric stoves, dehumidifiers, automobiles,
and multi-split heat pumpsError! Bookmark not defined..
24 “Korea Eco-Label Program and Green Supply Chain Related Activities” (Submitted by Japan); Dialogue on APEC Cooperation Network
on Green Supply Chain, May 2015
25 “Korea’s Energy Standards and Labeling: Market Transformation”; Korean Ministry of Knowledge Economy and Korea Energy
Management Corporation
The general formula used to calculate the efficiency index of a cooling product is presented below Error! Bookmark not d
efined.
        .
SUMMARY OF DISCUSSION
    1. India has voted in favour of the ISO 14067, which deals with carbon foot-printing of products. Additionally,
       ecolabeling criteria already exist for 18 product categories (which does not include cooling appliances).
    2. Ecolabeling criteria for cooling devices and equipment can be added to the current list of Ecomark criteria.
       The feasibility of this step and future roll-out mechanisms have to be formulated.
    3. The BIS welcomes the incorporation of life cycle assessment methodologies in drafting this set of ecolabeling
       criteria. Additionally, it also supports the development of a multi-criteria model for the proposed ecolabel (the
       label will measure pollution, human toxicity, global warming, waste management, and acidification, among
       others).
    4. A meeting was previously convened by the MoEFCC to discuss the Ecomark, and the BIS was an integral
       part of the discussion.
    5. For the proposed ecolabel, the MoEFCC could assist in creating the framework, and BIS will manage the roll-
       out and administration.
    6. The key environmental impact categories to be focused on for cooling appliances and equipment are: global
       warming potential, human toxicity, emissions, and energy consumption. The uptake of the future label has to
       be discussed, market dissemination strategies must be adopted for accelerated roll-out, and cost-
       effectiveness must be ensured throughout the process.
SUMMARY OF DISCUSSION
    1. A PowerPoint on Ecolabeling was presented to Dr. Amit Love of the Ozone Cell, MOEFCC. Dr. Love was
       supportive of the concept and offered suggestions to take the implementation of such a program forward.
    2. Ecolabeling criteria for cooling devices and equipment can be added to the current list of Ecomark criteria,
       as Ecomark currently does not cover cooling equipment.
    3. Continuous engagement with manufacturers is essential to explore the feasibility of incorporating such a label
       in India.
    4. A meeting was previously held with BIS to discuss the feasibility of the implementation of such a program,
       and the Bureau was supportive of the idea. However, the mandate of such a program has to be obtained
       from MOEFCC.
    5. For the proposed ecolabel, the MoEFCC could assist in creating the framework, and BIS will manage the roll-
       out and administration.
    6. The key environmental impact categories to be focused on for cooling appliances have to be decided upon
       holding future stakeholder consultation workshops. There is scope to integrate the requirements of such an
       ecolabel within the National Cooling Action Plan for India.
Meeting at UNDP
A meeting was held at UNEP to discuss the feasibility of incorporating ecolabeling criteria for cooling devices in India.
SUMMARY OF DISCUSSION
    1. A discussion on the feasibility of the institution of an ecolabeling program for cooling appliances in India was
       held with Mr. Atul Bagai of UNEP. He is of the opinion that introducing such a program is feasible, and is also
       necessary to introduce transparency within the environmental compliance sector.
    2. MOEFCC’s prior experience with ecolabeling has not been up to the mark, and it is essential to study the
       roadblocks faced earlier and formulate a feasible ecolabeling implementation plan.
    3. The proposed program could also incorporate climate change mitigation into its criteria.
    4. A meeting was previously held with BIS to discuss the feasibility of the implementation of such a program,
       and the Bureau was supportive of the idea. However, the mandate of such a program has to be obtained
       from MOEFCC. Additionally, Ecomark has to be studied in detail to identify challenges to roll-out.
    5. For maximum effectiveness, creating a voluntary program will aid the uptake; certain mandatory provisions
       could also be drafted. Top-rated products and manufacturers could be targeted for the initial roll-out.
       Approaching NITI Aayog could aid in the implementation.
    6. The key environmental impact categories to be focused on for cooling appliances have to be decided upon
       holding future stakeholder consultation workshops. Disposal mechanisms should be a particular focus.
    7. The effect of the proposed ecolabeling program on international trade has to be studied closely.
Meeting at MOEFCC
A meeting was held at MOEFCC to discuss the feasibility of incorporating ecolabeling criteria for cooling devices in
India, and the possibility of integrating the proposed ecolabel within the mandate of the Ministry.
SUMMARY OF DISCUSSION
    1. A discussion on the feasibility of the institution of an ecolabeling program for cooling appliances in India was
       held with Mr. Gyanesh Bharti of UNEP. He is of the opinion that introducing such a program is the need of
       the hour for India, and a specific focus on cooling is essential.
    2. It is essential to study the roadblocks faced earlier and formulate a feasible ecolabeling implementation plan.
    3. An introduction to CLASP and the Ecolabeling study was provided by Dr. Archana Walia to Mr. Bharti. She
       also stressed on the importance of going beyond energy efficiency and integrating other allied environmental
       measurement parameters within the proposed ecolabeling program. Potential technical support for the
       effective roll-out of the program is available through CLASP and its partners.
    4. The proposed ecolabeling program will have to be included within the mandate of MOEFCC. Additionally,
       Ecomark has to be studied in detail to identify challenges to roll-out.
    5. For maximum effectiveness, creating a voluntary program will aid the uptake; certain mandatory provisions
       could also be drafted. The proposed program should be amenable to include other product categories in the
       future.
    6. The key environmental impact categories to be focused on for cooling appliances have to be decided upon
       holding future stakeholder consultation workshops.
Appendix D: Additional Information – Life Cycle Assessment (LCA) for Air
Conditioners
Different sectors and products are energy and resource-intensive during varying life cycle stages. Based on this, all
products and services can be broadly classified into five categories 26:
        Raw Material Intensive Product: This product generates the most impact on the environment during the
         extraction of its raw materials, and such products typically consist of raw materials such as raw metals, natural
         extracts, bricks, and concrete.
        Manufacturing Intensive Product: Such products consume the most resources and generate the most
         waste during the manufacturing and processing of raw materials. Such products also typically tend to have a
         greater social impact, for example, the manufacturing of such products could potentially disrupt the local
         community’s access to some raw materials. Examples of such products include consumer durables, such as
         ACs, and chemicals.
        Distribution Intensive Product: These products have the maximum impact when they are distributed to
         different retailers in several regions. Such products also involve heavy packaging, which adds to their
         environmental impact. Examples of these products include fresh vegetables and fruits.
        Use Intensive Product: Such products have the most environmental impact during consumption. These
         products are also typically extremely durable and go through multiple cycles of use. One example of such a
         product is an automobile.
        Disposal Intensive Product: These products generate the maximum impact during disposal, are typically
         non-biodegradable, contain hazardous substances, and are difficult to dispose of in a safe manner. Examples
         of such products are different types of batteries.
Cooling devices are generally manufacturing-intensive and use-intensive. By taking into account the activity of a
particular device or equipment over its life cycle, and along the entire supply chain, potential areas of improvement
could be identified, and the minimization and levelling of environmental burdens from one life cycle stage to another
can be effected.
Benefits of the LCA Approach
1. Efficient industrial and manufacturing processes, enhanced occupational health and safety
2. Better policy creation and implementation frameworks for governmental agencies
3. More awareness for consumers, increased uptake of ecofriendly products and services
Life Cycle Climate Performance (LCCP) Indicator for air conditioners
The concept of Life Cycle Climate Performance for air conditioning and refrigeration centers around the following
parameters27:
The LCCP indicator comprises a rigorous approach to identifying and quantifying direct and indirect environmental
impact. The general formula for calculating LCCP is:
26“A Review of LCA Methods and Tools and their Suitability for SMEs”; Hannele Lehtinen et al., University of Manchester
27“Review of Life Cycle Climate Performance Analysis and IIR Working Party”; Yunho Hwang; Center for Environmental Energy
Engineering at the University of Maryland
GWP (indirect) = energy consumption (in CO2 equivalents) emissions from chemical production and transport,
manufacturing components, vehicle assembly, and end-of-life.
LCCP serves as a holistic measure of the emissions throughout the life of an air conditioning system. It gives an
accurate evaluation of the global warming impact of different HVAC&R systems; it calculates emissions generated
over the lifetime.
Appendix E: List of Products Certified Under Ecomark
The first Ecomark label was awarded to “Ezee”, a liquid detergent manufactured by Godrej. 3 The complete list of
products and organizations that have been awarded the Ecomark certification has been provided below.28
Table 6: Current Ecomark Licensees