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About Marine Fish PEFCR

The development of a Product Environmental Footprint Category Rule  (PEFCR) for Marine Fish started in 2014 as a part of the second wave of PEFCRs pilots, and it continued until May 2016 when it was decided to stop the process as it became clear that it did not exist the necessary data to develop a Marine Fish PEFCR in compliance with the requirements of the PEFCR Guideline and due to time-constraint it was unmanageable to finish within the timeline of the Pilot phase.

At that stage, a draft PEFCR had been through public consultation and thorough review by independent Life-Cycle Analysis (LCA) experts appointed by the EU commission. The work was summarised in a report that gave recommendations for a PEFCR for Marine Fish Products.

A Product Environmental Footprint Category Rule (PEFCR) can be understood as a set of rules that specify how the Product Environmental Footprint (PEF) method shall be applied for a specific product category. E.g. there are distinct differences between the environmental profile of a seafood product and that of a battery, and thus the rules for how their environmental footprint shall be calculated and documented needs to be specified.

The PEF method is a Life Cycle Assessment (LCA) based method to quantify the relevant environmental impacts of products (goods or services). It builds on existing approaches and international standards. The development of PEFCRs is a part of the EU policy for sustainable production and consumption. The “single market for green products” policy, that intend to make the environmental properties of product a part of its economy. To be able to achieve that, the environmental footprint of the product has to be calculated and documented in terms of a set of known and trusted rules, a PEFCR.

A PEFCR is developed according to a PEFCR Guidance document (the current version is 6.3) that defines the requirement to the organisation and the process of developing a PEFCR. PEFCRs should be developed and written in a format that persons with technical knowledge (in LCA as well as with regard to the considered product category) can understand it and use it to conduct a PEF study. The PEFCRs shall implement the materiality principle, meaning that a PEF study shall focus on those aspects and parameters that are the most relevant in determining the environmental performance of a given product.

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The PEFCR shall cover marine fish for human consumption in the EU market. The rationale for this scope is explained in the following text. This scope is considered as wide as there are a single main function but different applications/technologies/materials.

The function of the product is to provide a meal for human consumption. The scope is defined with respect to the stated goal by the PEFCR Guidance v 6.3 (chapter 1.7): “Pilot testers are advised to define an as broad as possible scope for the PEFCR, including all products that are capable of fulfilling the same function. A too narrow (small) product category definition would result in a very large number of PEFCRs, diminishing the usefulness of the developed PEFCRs. In its extreme, it could lead to meaningless PEFCRs.

This goal must however be considered with respect to the requirements to data quality and representativeness. The reason why the scope is limited to a specific list of fisheries is a consideration of the data that is available against the sum of requirements on representativeness and data quality in the PEFCR Guidance.

Based on the previous attempt to develop a Marine Fish PEFCR, and more than a decade of experience with LCA of seafood producing systems, we think that the seafood LCA data that is available, even though limited, is sufficient to perform the necessary screening and supporting studies, and to make a robust and responsible PEFCR for marine fish.

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