In one of the most notorious cases, known as the Dieselgate scandal, the United States Environmental Protection Agency issued a notice of violation of the Clean Air Act to a leading car manufacturer for intentionally programming its diesel engines to activate emissions controls during laboratory testing in order to meet regulatory requirements. Under normal driving conditions, however, the vehicles emitted up to 40 times higher pollution levels.
However, not all cases involve illegal action on the part of the manufacturer. Rather, ambiguities in the representativeness of testing conditions or in the testing boundaries can lead to disagreement over testing results. In another incident, a British manufacturer challenged the energy efficiency labelling laws in the Europe Union, arguing that the testing conditions used for vacuum cleaners did not reflect real-life use.
Regulators rely on testing standards to determine the environmental performance of a product. Testing standards influence consumer decisions and impact industry competitiveness. However, as noted by Solange Blaszkowski, the Chair of the IEC Advisory Committee on Environmental Aspects (ACEA), “The way testing procedures are designed will influence the outcome of the test itself. It is therefore key to guarantee that these test methods represent the way consumers use the product.”
In addition, as technology develops rapidly, user habits change and products integrate more functions, testing standards may need to be revised more frequently and with a clear definition of boundaries. And, given the recent incidences with certain environmental testing regimes, it may be necessary to ensure that the trust of the users in IEC testing standards remains intact. “In view of these events, ACEA concluded that it was of paramount importance that our standards would not be subject to discussions in terms of credibility. So in 2017, we started drafting a credibility guide,” remarked Blaszkowski.
The Guide to securing the credibility of IEC publications containing environmentally relevant provisions is applicable to all IEC publications that contain test methods used to assess environmentally relevant provisions.
The Guide defines environmentally relevant provisions as those that measure an impact upon the environment. According to the taskforce leader developing the guide, Jens Giegerich, “This impact can appear due to the use of resources like energy, water and material or due to the emission into the air, water and soil that has an adverse impact on the environment.”
Environmental impact can be either direct or indirect. Direct environmental impact includes, for example, the direct emissions of greenhouse gases during any of the lifecycle phases of the product. Indirect impact can be generated by the consumption of energy or other resources. As Giegerich clarified, “While the use/consumption of electric energy does not pose a direct impact on the environment, the way the energy is generated does.”
To help standards developers determine whether to classify a test provision as environmentally relevant, a flow chart has been developed as a guide. “If any of these questions can be answered in the affirmative, then the Guide is applicable,” explained Giegerich.
The Guide assesses credibility based upon well-known testing principles. “The principles of repeatability, reproducibility, accuracy of the measurement and cost are typically well known by IEC committees”, notes Giegerich. However, these principles are not sufficient to determine the environmental credibility of a test provision. For this reason, the Guide introduces two further concepts: representativeness and anti-circumvention.
Representativeness focuses on how realistically a test addresses the real-life use of a given product. It considers aspects such as geographical location, user expectations, usage period and technology coverage. According to Giegerich, “Representativeness can be described as a quantitative assessment of the degree to which a provision reflects the true population of interest. However, the representativeness of a test provision can change over time, meaning that a test provision which is representative at one point in time might not be representative at a later point in time”.
The Guide calls for the integration of test provisions that minimize the risk of circumvention. Circumvention, defined as an activity that results in an advantageous and invalid outcome to an assessment, can be intentional or unintentional. “Testing methods that are not clear or give opportunity for multiple interpretations are prone to be misused, or, in other words, to be circumvented. When drafting test provisions it is imperative to address and minimize the risk for circumvention,” notes Blaszkowski.
Given the speed of technology advancement, the changes in user expectations and behaviour, and the integration of product functionalities can result in the need to revise publications more frequently than is currently the case with IEC publications, “Shorter stability dates may be required,” remarks Giegerich.
To help with these new concepts, the Guide provides assistance on how to draft test provisions that address real-life representativeness and minimize the risk of circumvention. As Giegerich notes, “If all of these principles are followed, it can be assumed that a test provision is credible.”
A draft of the Guide has now been circulated to all IEC committees for their comments. These comments will be resolved, and the Guide will then be circulated to the SMB as a QP (Question of Principle). Any comments will be resolved by the ACEA Taskforce, and the Committee Draft Guide will be prepared, edited and submitted for translation, following which it will be circulated to National Committees for a 12-week ballot. The Guide is expected to be published in the second quarter of 2021.
It will be essential that IEC committees consider fully their test methodology and ensure that they remain credible. As noted by Blaszkowski, “We need to maintain or perhaps regain the trust of users in environmental performance claims about products. Environmental performance related test standards should therefore provide users of products with the same level of certainty as, for example, that for safety.”