Biogenic carbon in the current PEF rules
In the currently proposed methodology of the Product Environmental Footprint rules addressing biogenic carbon, there is no recognized benefit granted to the producers of biomass-derived products, compared to fossil ones.
In a cradle-to-grave approach, the biogenic uptake and emissions of CO2 from disposal are balanced. Therefore, in such a cradle-to-grave approach, biomass derived products will not receive any CO2 burden when they are disposed of, while fossil products will receive a CO2 burden in case of incineration.
However, in a cradle-to-gate life-cycle analysis using PEF methodology, biomass-derived products will not receive any credit for the fact that CO2
was removed from the atmosphere during photosynthesis and plant growth. Whereas in LCA (ISO 14067, EN 15804 and other LCA standards
) biogenic CO2
uptake in biomass-derived products shall be addressed.
When the use of the product cannot be singled out - like platform chemicals which are used for a range of different other products or intermediates -, the manufacturers need to supply a cradle-to-gate LCA. Accordingly, there will be no CO2 credit for biobased raw materials calculated at the gate of the product. It will look like there is hardly any benefit from producing biomass-derived products if any at all, compared to fossil based.
The same “accounting” problem appears when biomass feedstock is blended with fossil feedstock, like in mass balance scenarios. There will hardly be any difference in greenhouse gas footprints as long as a cradle-to-gate assessment is used for life-cycle inventories and for full LCA where other forms of end-of life approaches than incineration are applied. Additionally with the current approach, the use of the products in long-lasting applications, investment goods and others are not considered as an actual removal of biogenic CO2.
The figures (fig. 1 and 2) below illustrate this method used for an imaginary product made of both fossil- (grey) and bio-based (green) feedstock. For simplicity, we assume exactly the same CO2 footprint in production and logistics for these two feedstocks, as well as the same manufacturing processes and the same final uses. The only difference is in the CO2 emissions at end of life, where biobased feedstock emissions are zero and fossil-based ones are substantial (= 100 in this scale). We easily see that there is no difference for cradle-to-gate LCA or for everlasting or recycled products that never will release CO2. This is counter-intuitive since we all know that CO2 was fixed during growth of the biomass and has not yet been released again until end of life.
ISO 22526-1, ISO 22526-2, ISO 22526-3, EN 16760