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MODULE 5: PLASTIC CREDIT RELATED CLAIMS

References Documents:

 

1. ISO (2016). ISO 14021:2016 – Environmental labels and declarations – Self-Declared Environmental Claims (Type II environmental labelling)

2. UNEP (2017). UNEP Guidelines for Providing Product Sustainability Information

3. Plastic Footprint Network (2023). Plastic Footprint Guidelines Version 1.

PCX Solutions encourages companies and businesses to eliminate or reduce non-essential and avoidable plastics by utilizing upstream solutions, where feasible. For plastic wastes that currently cannot be eliminated, avoided, or reduced, PCX Solutions encourages companies to take responsibility for their plastic footprint through various solutions, such as Plastic Credits.

 

If companies want to communicate their actions to address plastic pollution through self-declared environmental claims, they should adhere to the highest level of transparency and integrity and take full responsibility for their communication. PCX Solutions only provides recommendations and guidance based on global best practices and consensus on responsible environmental claims. A Plastic Credit Buyer's adherence to the guidelines set forth in this Module 5 of the PPRS shall not equate to PCX Solutions' endorsement nor approval of their environmental claims.

 

Recommendations For Self-Declared Environmental Claims

 

PCX Solutions recommends aligning any self-declared environmental claims to the requirements set forth in ISO 14021:2016 – Environmental labels and declarations – Self-declared environmental claims (Type II environmental labelling)[36]. As defined in the requirements of ISO 14021, claims should neither be misleading, subject to misinterpretation, nor overstated. Claims should also be measurable and verifiable with a clear and transparent methodology for the basis of the claim. All elements of the claim should be substantiated and should be accompanied by an explanatory statement.

 

Companies can also adhere to the fundamental principles of the UNEP Guidelines for Providing Product Sustainability Information[37]:

  • Reliability

  • Relevance

  • Clarity

  • Transparency

  • Accessibility

 

In general, claims should be balanced—i.e. not only communicate positive aspects and impacts, but also to detail how adverse impacts of an organization’s product or service are reduced by the positive impacts achieved through e.g. financing Project(s) under the PPRS. The claim should also detail the contribution of a PPRS Project in mitigating plastic pollution in relation to the company’s overall strategy to address plastic pollution.

PCX Solutions will not approve or certify any self-declared claims, but provides guidance based on best practices. Plastic Credit Buyers are solely responsible for any and all claims it makes as regards its plastic footprint and Plastic Credit retirements.

If a credit buyer wishes to use any trademark or asset owned by PCX Solutions, communicate its partnership with PCX Solutions, or support its Project Partners and their Projects, approval is needed by the relevant entity. Documented consent must be secured from the Project Partner directly or through their platform/intermediary if there are self-declared environmental claims made with regards to the Project’s co-benefits. Separate guidance will be provided to Plastic Credit Buyers.

Impact Communication 

 

Plastic Credit Buyers can choose to purchase Plastic Credits from specific Projects to support its objectives or socio-economic benefits, such as upscaling plastic waste collection and conducting educational awareness programs on plastic waste management. The co-benefits of each PPRS Registered Project varies from Project to Project, and thus certain linkages of benefits derived from a registered Project may only be made when investments of the Plastic Credit Buyer are linked to that specific Project, and only when the claimed co-benefit of the project has been independently audited.

 

Coordination with either the Project Partners or their authorized platform or intermediary must be done to determine the specific impact of the Plastic Credit Buyer’s investment relative to the Plastic Credit funding structure of the Project. Only those impacts and co-benefits which have been validated and verified by the Project’s VVB can be claimed. Each Project must be willing to disclose the method(s) and information necessary to substantiate and verify the claim. Claims must quantify the impact being communicated (e.g. it cannot claim the benefit of the entire Project that recycles 100 MT, when it has purchased only 10 MT).

 

Footprint Methodology Considerations 

 

PCX Solutions provides guidance for computing an organization or brand’s plastic footprint, based on prevailing methodology in countries with EPR. However, we acknowledge that there is yet to be a global consensus on the appropriate plastic footprint methodology, both on a general level and on a sectoral level. Any claims in relation to a calculated plastic footprint should be accompanied by explanatory information to declare the methodology used, the scope of the plastic footprint assessment done, and if it has been subjected to a third-party verification. The scope should include the time period for the data used, and the covered products, packaging, brands, activities, components, and its geographical and system boundaries.

 

PCX Solutions recommends Plastic Credit Buyers to seek third-party verification for footprint declarations and methodologies in order to have assurance on the veracity and appropriateness of their declared footprint.


In an effort to ensure transparent and reasonably reliable calculations of the plastic footprint, the following considerations are highlighted:

Defining Boundaries

 

Clearly defining the boundaries for the plastic footprint is critical to ensure its relevance and applicability to various contexts. It should be tailored to meet the specific needs and objectives of the assessment, which may vary, depending on the region of application, intended use (internal versus external), and the purpose of the assessment (e.g. disclosure, decision-making, and monitoring). A comprehensive definition of boundaries enables organizations to accurately quantify their plastic usage.

 

Measurement Methodology

 

In recognition of the absence of a global consensus on a universally accepted plastic footprint methodology, the PPRS underscores the importance of adopting a conservative approach in selecting an appropriate methodology for calculating the plastic footprint. Utilizing the amount of plastic products purchased by the reporting company as the basis for the plastic footprint is regarded as the most conservative method. This approach ensures a clear and unambiguous definition of the input data and the assumptions required for calculation.

 

In contrast, methodologies based on plastic products sold may introduce uncertainties, particularly when accounting for returned products. Alternative methods, such as computations based on sales or projections, may lack the clarity and verifiability inherent in the conservative approach.

 

Plastic Credit Buyers may consider the following best practices when choosing the appropriate methodology[38]:

 

  • Defining Boundaries: It is highly recommended to delineate organizational and operational boundaries prior to calculating a plastic footprint. This practice is particularly crucial for larger entities with multiple subsidiaries, as it facilitates a structured, transparent, and comprehensive evaluation process.

  • Categorizing Footprint: Footprints are encouraged to be categorized based on the extent of organizational control (direct control, indirect control, influence). This aids in evaluating the organization's impact and responsibility in footprint reduction, thereby emphasizing upstream mitigation measures and adopting a holistic approach to addressing their footprint.

  • Data Quality and Granularity: The quality and granularity of data should be assessed in accordance with the intended use of the plastic footprint. Ensuring data accuracy and consistency is vital across plastic footprint assessments. An iterative approach to data quality improvement is recommended, starting with available data and progressively enhancing its quality as needed.

 

Transition from Net Zero Plastic Waste (NZPW)

 

Previous versions of the PPRS authorized the use of the specific claim, “Net Zero Plastic Waste,” to communicate that a company or brand has taken responsibility for 100% of its declared and verified net plastic footprint. While we maintain that the methodology used to certify those claims was sound, we also recognize that there has been no global consensus on the terminologies surrounding “net zero” for plastic, and in the same way, there is currently no globally accepted, science-based approach for the determination of a plastic footprint, which should ultimately serve as the basis for any “net zero” or “neutrality” claim. 

 

In this regard, PCX Solutions is putting any further certification of claims surrounding “net zero” on hold until a global mechanism has been established. This decision has been made with a conscious effort to work with various stakeholders and international organizations in strengthening the credibility of Plastic Credits and harmonizing the understanding of any “net zero” claims. This effort is also consistent with our desire to protect Plastic Credit Buyers and Project Partners from reputational risks and regulatory repercussions.

 

Since the Net Zero Plastic Waste (NZPW) Certification had a previous minimum commitment of three years, companies, brands, and organizations with active and valid certifications may continue to use the NZPW badge and associated authorized claims, provided it continues to comply with the requirements of Module 5, version 7 of the PPRS and the signed terms and conditions of the NZPW certification. At the end of the three-year period for which a company has committed to this certification scheme, they will be required to remove all associated badges and claims on-pack and applicable channels (website, social media, ads, etc.).

 

In the case that the Plastic Credit Buyer wishes to use any trademark or asset owned by PCX Solutions, they should adhere to the guidance provided in this module.

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[36] ISO (2016). ISO 14021:2016 – Environmental labels and declarations – Self-declared environmental claims (Type II environmental labelling)

[37] United Nations Environment Programme (2017). Guidelines for Providing Product Sustainability Information: Global Guidance on Making Effective Environmental, Social and Economic Claims, to Empower and Enable Consumer Choice. https://wedocs.unep.org/bitstream/handle/20.500.11822/22395/product_sust_info_2017.pdf?sequence=8&isAllowed=y

[38] Plastic Footprint Network (2023). Plastic Footprint Guidelines Version 1.

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