1 Introduction
In 1991, the German government adopted the Packaging Ordinance, establishing the responsibility of manufacturers for the disposal of their products and regulating the use of disposable and reusable packaging and mandatory deposits (Groth
2010). Since 2005, the European Union (EU) has sought to increase the environmental performance of energy-using products with its Ecodesign Directive (EC
2009). The US government’s 2022 General Services Administration Low-Carbon Standards require project contractors to provide environmental product declarations (EPDs), meeting 20% lower embodied carbon limits for concrete, and using “environmentally preferable techniques” for asphalt (Clean Energy Canada
2022). What do these proposals have in common? All are public policies that aim at reducing environmental harm and all are based on life cycle assessment (LCA).
LCA is an instrument to assess the potential environmental impacts and resources used throughout a product’s
1 life cycle, that is, from raw material acquisition, through production and use stages, to waste management (ISO
2006). As a holistic and comprehensive approach, it comes with the promise of avoiding the displacement of environmental impacts from one stage of the life cycle to another since the entire cycle of a product is taken into consideration (Hellweg and Milà i Canals
2014).
The use of LCA has grown significantly over the past three decades to assess and improve environmental performance and inform environmental decision-making in various industries. Consumer demand for better product information explains this growing interest (Jensen et al.
1998; Valdivia et al.
2011) but also demand for quantitative science-based climate targets (Morseletto et al.
2017; Walenta
2020). Via standardization processes, LCA is now part of the sustainability toolkit in the private sector, backed by big companies like Alcoa, Rio Tinto, or Unilever, while accounting firms like Deloitte, PwC, Ernst and Young, or KPMG offer LCA consultancy (Freidberg
2015b).
But what about the public sector? To what extent has LCA been added to the environmental policy toolkit of governments? With the increasing importance of target setting and science-based environmental and climate policymaking, the need for tools to measure and quantify has increased, too (Bjørn et al.
2021). We review the current state of affairs of LCA use in public policy, and gauge how, beyond anecdotal evidence, LCA has indeed penetrated public policymaking through its incorporation in different policy instruments in various sectors. We then discuss what this penetration means for environmental policymaking and sketch out a research agenda on the role of politics in the deployment of LCA.
While our focus is on LCA as an internationally standardized methodology according to the ISO 14040 and 14044 series standards for assessing environmental impacts (Bjørn et al.
2018), we include literature that occasionally refers to other life cycle connotations. This literature may include life cycle thinking (LCT) as a more ideational than quantitative way of conceiving environmental, economic, and social consequences throughout the life cycle of a product, but also other life cycle approaches like product environmental footprints (PEF) or environmental product declarations (EPDs).
2 We highlight the differences if they are important to our discussion.
When speaking of public policy, we refer to “anything a government chooses to do or not to do” (Dye
1972: 2). Governments make authoritative decisions on behalf of citizens, even though non-governmental actors from business and society regularly intervene in the policymaking process to influence decisions. In specific circumstances, the implementation of policy decisions may be left to non-governmental actors (Howlett and Cashore
2014). Governmental action relies on policy instruments, that is, on governance tools and techniques by which public authorities exercise power to structure collective action and induce social change (Acciai and Capano
2021). Our focus here is on policy instruments that relate to LCA.
We start with a short historical overview of the industrial origins of LCA (1) before reviewing the literature on LCA from a public policy and social science perspective (2). The discussion and the outline of future research directions (3) are based on a literature review backed with information from a dozen interviews that were conducted in 2022–2023 with LCA experts from government, consultancy, and academia covering France, Germany, Switzerland, and the EU.
2 The industrial origins of LCA
LCA made its appearance in the 1960s. Initially called Resource and Environmental Profile Analysis (REPA) or Ecobalance, the focus was on packaging and, from the beginning, the effort was industry-led. In 1969, for example, Coca Cola commissioned—for internal purpose—a study to compare aluminum, plastic, and glass bottles. But with the development of environmental policies in the 1970s, governments soon became involved. In 1974, the Environmental Protection Agency (EPA) commissioned the first public and peer-reviewed LCA study on beverage container alternatives with the aim to inform American regulation. The EPA concluded on its impracticability because too many products would need to be assessed, implying far-reaching micro-managing of private businesses (Bjørn et al.
2018).
After the OPEC oil embargo, in the second half of the 1970s, LCA was more prominently applied to energy use (Hunt et al.
1996). LCA lost steam in the 1980s; one reason was the lack of standardized data sets and databases, which made it difficult and expensive to perform LCAs. The approach regained popularity in the 1990s, as methodologies and sector-specific life cycle inventory databases were developed in different locations. At first, LCA addressed environmental problems like solid waste, energy use, and air and water emissions to respond to emerging and changing public concerns. LCA became the common term—even though German-speaking countries still refer to ecobalances. According to Bjørn et al. (
2018, p. 20), “the ambition has since then been to quantify all relevant environmental impacts, independent of shifting public concerns, with the goal of avoiding burden shifting.”
With growing interest for LCA in North America, Europe, and Japan, the need for improving and harmonizing methodology and data also increased. The Society of Environmental Toxicology and Chemistry (SETAC) backed the codification efforts of LCA practices by organizing workshops for representatives from business, government, and academia and by supporting the preparation—and later revision—of the standardization process under the International Organization for Standardization (ISO) (Fava et al.
2014). Starting in 1993, the standardization process led to the adoption of a common framework and principles (ISO 14040) in 1997, which are regularly updated. Three other ISO standards have been integrated into ISO 14044 in 2006, specifying requirements and guidelines (Hauschild and Huijbregts
2015). Aside from the ISO 14040 series, the ISO 14000 series of Environmental Management Standards about ecodesign, communication of environmental performance, and greenhouse gas reporting and reduction also address LCA (Bjørn et al.
2018). Freidberg (
2013: 574) points out that ISO standards do not ensure uniformity in practice or interpretation of LCA but they “gave LCA a degree of much-needed credibility.”
Beyond governments and experts, industry also developed links with international organizations. In the late 1990s, SETAC established a partnership with the United Nations Environment Programme (UNEP). Launched in 2002, the UNEP/SETAC Life Cycle Initiative (LCI) seeks to promote LCA on a global scale, contributing to capacity building and helping to make LCA data more accessible and consistent (Sonnemann et al.
2018). Hosted by UNEP, the Initiative is a partnership of institutional members from government, business, science, and civil society. In its 2022–2027 strategic approach, the Initiative focuses on high-impact intergovernmental or sector-specific processes for sustainable development (
www.lifecycleinitiative.org).
4 The missing politics of LCA: filling the research gap
Our literature review confirms that LCA is far from limited to the private sector and is increasingly used in public policymaking. Freidberg (
2015b, p. 175)’s interviews with practitioners reveal that they perceive governments’ interest in LCA to be more significant than corporate initiatives, policy measures to be more important than efforts by consumers or retailers, and policy settings to provide better opportunities to explain complex findings. Interestingly, though, LCA is rarely visible on political agendas. Perhaps as a result, LCA also occupies very little space in the otherwise rich literature on environmental policy instruments (e.g. Mol et al.
2000; Jordan et al.
2012; Van der Heijden
2012; Wurzel et al.
2013; Parson and Kravitz
2013; Rogge et al.
2017).
Yet, being in the shadow of politics does not mean that politics does not matter. Politics can impact LCA and life cycle approaches in several ways. Social scientists have already pointed to the importance of embedding LCA and life cycle approaches in their social and institutional context. For example, Newell and Voss (
2011) investigate carbon footprint modelling in the global paper industry and observe that the LCA-based approach neglects complexities of scale and scope by delineating system boundaries in a narrow way. Jordan and Bleischwitz (
2020) focus on embodied emissions in the construction sector, where EPDs and PCFs can enhance the accountability of the value chain of products, and investigate how these informational devices are perceived by various actors who can promote or block their adoption. They conclude that, to fulfil their potential as sustainability devices, EPDs and PCFs require legitimation. But they also find tensions between underlying legitimation logics. Jordan (
2021) examines EPDs and PCFs in the construction sector and shows how coordinated sectoral responses to environmental policy increase the availability of life cycle data: the institutional context generates incentives for an intra-sectoral exchange on the environmental impacts of production. This is conducive to the creation of sectoral life cycle data sets and leads to the reduction of transaction costs for the creation of sectoral EPDs, thereby favoring the diffusion of ecolabels.
These contributions are an important step towards understanding the social and institutional underpinnings of the use of LCA and life cycle approaches, but they do not put politics front and center. This gap needs to be filled if one is to realize the full potential of LCA in public policy, for four reasons: the importance of societal values, the challenge of private/public governance, state capacity, and political agency. Our argument is informed by insights from social and political science as well as a dozen interviews that were conducted in 2022–2023 with LCA experts from government, consultancy and academia covering France, Germany, Switzerland, and the EU (ethics approval for these interviews was obtained from our university).
The first reason has to do with the fact that policy instruments embody values which deserve political attention (Lascoumes and Le Gales
2007). The role of value judgments recurrently haunts LCA practitioners (e.g., Schmidt and Sullivan
2002; Hofstetter
2002; Nathan and Coles
2020). In
From behind the curtain: talking about values in LCA, Freidberg (
2015a) unveils the tension between the “objective” natural science ambitions and the value-based judgments of LCA practitioners and encourages the latter to take responsibility of their value choices. Inspired by the post-positivist argumentative turn that calls into question the assumption that the analysis of public policies is technical and value-independent (Fischer and Forester
1993), Bras-Klapwijk (
1998) also stresses the tension between the argumentative, discourse-oriented policymaking process and LCA’s aspirational logic of objectivity and quantification. She considers LCA’s exclusively rational approach to be problematic for environmental policies and suggests including facts and values in the deliberation process. In the same vein, Seidel (
2016) pleads in favor of a more inclusive and collaborative stakeholder process and encourages life cycle
thinking among policy makers, even if this does not result in a full LCA.
The second reason why politics matter relates to governance. The literature and our interviews make clear that the industry has been a key driver in LCA deployment, and its interest is likely to increase in the context of supply chain governance. LCA is embedded in industries, and industries are actively involved in standardization processes. For example, it is not uncommon that firms (e.g., BASF, VW) provide the chairperson for the ISO-Committee TC207/SC5 Environmental Management – Life Cycle Assessment. The involvement of the private sector in environmental governance is neither a new nor a rare phenomenon: private actors participate in various ways, their implication in ecolabelling and certification being the most prominent example. In LCA, it can be compared to what Jessica Green (
2014) calls private entrepreneurial authority, a form of polycentric governance whereby numerous private actors mobilize their shared, recognized expertise to impose rules without an explicit delegation of authority by the state. This form of authority applies well to LCA, where industries provide data, increasingly invest in inhouse capacity, contribute to the development of methods, and frame priorities.
While self-regulation may contribute to a public good, leaving LCA implementation to private actors is in and of itself a political decision with significant consequences. For some of our respondents, there is no problem when type III environmental declarations (presenting quantified environmental information on the life cycle of a product) are mostly self-regulated, “business-to-business.” But the rapid development of private entrepreneurial authority may become problematic if it is no longer seen as legitimate in the public eye. Examining the rise of LCA as a supply chain governance tool, Freidberg (
2013) has shown how LCA responds to the expectations of metrics-based governance, while fostering an expert community of representatives from industry, academia, and consulting. She argues that the food industry uses footprinting to legitimate supply chain governance and to “advance an understanding of ‘sustainable food’, that suits their own bottom-line interests” (Freidberg
2014: 179). Still in the context of supply chains, Freidberg (
2015b) has examined the challenges of producing LCA knowledge, while assuring its credibility. She illustrates how practitioners try to navigate industries both as clients and as key information providers. At a minimum, transparency should be a prerequisite to improve the credibility of processes and results.
But even if transparency is improved, there is a risk that private entrepreneurial authority ends up capturing public regulation. Some of our interviewees see the ISO standardization process as an entry point for lobbyists to establish certain accounting practices and methods, which can generate results that are not in the public interest. Interestingly, perceptions among our interviewees diverge depending on the country of origin. French respondents worry more about the potential loss of public control than respondents speaking about Germany, Switzerland, or the EU. The former are rooted in a more dirigiste tradition where the state steers industries, and where public policies are interventionist and centralized (Smith
2021). The latter are accustomed to corporatist concertation with private actors; that is, organized interests are more commonly privileged in the policymaking process and policymakers routinely deliberate, negotiate, and bargain with interest groups (Christiansen
2019).
The third reason why politics matters is that, despite the prominent role played so far by industry, state capacity is likely to be a crucial factor in the implementation of LCA-based public policy. Even when governments choose to delegate authority to private actors, they need to be able to monitor and eventually discipline private authority. Several interviewees are concerned that industry-led LCA practices might be rubberstamped by policymakers and public administrations who are ill-equipped to follow up due to their lack of expertise or resources. State capacity has multiple dimensions and definitions, but here we only focus on the effectiveness of state intervention, which requires a capable bureaucracy, good coordination, and coherence among state organizations (Rueschemeyer and Evans
1985).
In terms of expertise, we see variation between jurisdictions. French respondents in particular worry about the capacity of their authorities in term of personal resources and technical skills, or in the words of one civil servant: “My colleagues have to challenge Formula 1 drivers without having the appropriate expertise.” Germans seem less worried about inhouse capacity, mentioning a significant expertise within the German Environment Agency, which oversees quality control and is complemented by an important expertise in consumer protection. Some interviewees question, however, the practice of subcontracting and the dependency on external consultancy firms. We also see variation in terms of coordination and coherence among public organizations. In France, LCA expertise is concentrated at ADEME, the public environmental transition agency, which is perceived to be remote from ministries and policymakers. But coordination and coherence are also an issue elsewhere because environmental policy tends to be organized in silos. In the context of LCA in Germany and the EU, an interviewee speaks of a “beehive organization” where focus on details can prevent a more holistic view. In this regard, the Swiss’ recent attempt to establish a hub to support LCA activities within the administration could be a promising avenue.
Addressing the two key dimensions of state capacity, the 2023 White Paper from the US National Renewable Energy Laboratory recommends to establish a “dedicated and central curator for the Federal LCA Commons,” to invest in “professional association program support that ensures ongoing, nonpartisan guidance from and coordination with the LCA professional community from the public and private sector,” and to provide “privacy-preserving computation and secure date hosting technology platform that ensures sufficient technical tools for confidential and even-playing field participation from private industry,” as well as dedicated resources and formalization of the Federal LCA Commons. The White Paper calls for new resources to maintain and expand LCA in the context of recent green industrial initiatives (Feraldi
2023).
A fourth reason to pay more attention to the politics of LCA concerns political agency, notably the role played by political parties and interest groups. For Skocpol (
1985), state capacity is also the capacity to implement public goals over the actual or potential opposition of powerful social groups. Political leaders and policymakers may use life cycle thinking and rhetoric to signal their commitment to sustainability and environmental protection, as they have done with the connected concept of the circular economy (Schöggl et al.
2020). But standardization and the integration of LCA and life cycle approaches in legislation and regulation will induce costs with distributional consequences which are likely to be opposed and politicized. Regulations on renewable energy and carbon taxes were also discreet policy instruments before they were politicized by actors who positioned themselves for or against them in the public sphere, with important consequences for the implementation (or not) of these instruments (Cheon and Urpelainen
2013; Stokes
2020). For instance, Lockwood and Lockwood (
2022) show that right-wing populist parties are hostile to climate and renewable energy policies, even though they are more ambivalent about the latter. As they become more prominent in public policy, there is no reason to expect that LCA-based policies will avoid that fate. If these policies remain voluntary and industry-led, environmental NGOs and parties may deride them as cases of greenwashing, as is increasingly the case for ESG indicators. If public authorities push for more transparency or establish more stringent framework conditions for data or methods, as several interviewees wish for, economic interest groups that stand to lose out and anti-environmental parties may turn against them.
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