Comments to The Bulgarian Institute for Standardization about new ISO standard on carbon neutrality

A New Work Item Proposal (NWIP) has been put forward to ISO to develop a new standard on Carbon Neutrality. In summary:

This standard will specify the requirements to be met by an organisation, product, project, event, building, etc. seeking to pursue and demonstrate greenhouse gas, carbon or climate neutrality through the quantification, management, avoidance, reduction, substitution and compensation of GHG emissions. It will define terms used around ‘neutrality’ related claims and statements, including guidance on approach. It will establish principles for achieving and demonstrating carbon neutrality (including for example against which the selection of methodologies can be undertaken). The standard will be applicable to a wide range of situations (organisations, businesses, local government, products, services).

This standard will recognise that pursuing and achieving ‘neutrality’ through reduction of direct GHG emissions is imperative. The standard will not make provision for a declaration of the achievement of carbon neutrality solely through offsetting. The standard will include considerations concerning phased approaches and use of ‘neutrality’ related claims and targets. The standard will include requirements on, and provisions concerning, the declaration of commitment to carbon neutrality and for the declaration of the achievement of carbon neutrality. It will also include guidance concerning limitations and responsible use of ‘neutrality’ as a climate related claim. This will include important context considerations to help ensure transparent and responsible use of the term carbon neutrality, for example relative to the publicly perceived scope of the subject, and to considerations such as emissions over time and broader global context.

The standard will be developed in ISO under TC207/SC7. In order to play an active role in development of this standard CEMBUREAU and BACI feeded the following comments to BDS into the process. Comments on the NWIP are due to be submitted to ISO by 15th January.

  1. The proposal states that the standard will not make provision for a declaration of the achievement of carbon neutrality solely through offsetting. This raises a number of questions such as what is classed as “offsetting” and if 100% offsetting can’t be claimed to be carbon neutral then what percentage is acceptable and how is this determined? A clear definition of “offsetting” will be required here and will need to be carefully thought through. It would be worth considering a differentiation between permanent and temporary offsetting too.
  2. The NWIP mentions the reduction of direct GHG emissions (which we agree is vital) but it will also be important to consider the reduction of indirect emissions, particularly if the standard is going to include the carbon neutrality of buildings. For example, the use of concrete can reduce the energy needed to heat and cool buildings. Energy savings from the use of concrete have been shown to ‘pay back’ additional embodied carbon in concrete compared to other building materials, in just 11 years. This is an important consideration if the carbon neutrality of buildings is going to be covered by the standard.
  3. This leads on to the concept of time and carbon neutrality. As mentioned above, the potential reduction in indirect emissions results in a cumulative carbon saving over time. How will this be taken into account in any claims made? One suggestion is to allow the carbon neutrality claim to be on a timeline that is relevant to the functional timeline of the product, providing it is fully and transparently declared.
  4. How will the boundaries be set for any carbon neutrality claims? Will this be left up to the organisation to show what is and isn’t included in the supply chain? For example, could a claim be made for production of a product excluding its transport to customers, providing the boundaries are clearly stated? Ideally the scope should remain as broad as possible but there should be clear statements setting out what is and isn’t included so easy comparisons between materials/ projects/ products etc. can be made.