OpenLobby.EU
Explore

maki Consulting GmbH

maki

We offer life cycle method related services at the interface between industry and policy and particularly in the context of the European Commission’s Product Environmental Footprint (PEF) and it’s International Reference Life Cycle Data System (ILCD) Handbook and ILCD / LCDN Data Network, which we have both technically lead from 2005 to early 2012 while working at the Commission.

Lobbying Activity

Response to Carbon footprint methodology for electric vehicle batteries

28 May 2024

maki Consulting welcomes the publication of the draft Delegated Regulation establishing the methodology for the calculation and verification of the carbon footprint of electric vehicle batteries. We believe the methodology and data basis should be as robust as possible, ensuring valid comparisons. It should moreover incentivise companies to achieve best-in class, improving their products, including at suppliers. With our feedback focussing on selected methodological, data, and data quality aspects, we see the need for some amendments in these areas and make specific proposals. We have inserted our feedback directly in context of the text sections of the legal draft (after conversion into a Word document); please find the document attached.
Read full response

Response to European Critical Raw Materials Act

26 Jun 2023

maki Consulting considers a Critical Raw Material (CRM) Regulation (including for Strategic Raw Materials (SRM)) to be a suitable way to address supply risk to societys demand for critical and strategic materials. In fact, it is arguably both more relevant and more meaningful than current indicators on Resource depletion overall that look into extraction speed vs. (global) stock. As we are currently working on the topic from LCA /Environmental footprint method and data perspective, please find attached some specific feedback for improving the Regulation and its related annexes.
Read full response

Response to Sustainable Products Initiative

22 Jun 2022

maki Consulting welcomes the comprehensive legislation with its expansion to non energy-related products, its many options for measures to be selected and tailored for the specific product group (while considering the individual product’s characteristics). The tie-in with the complementary Green Claims initiative and using the Commission’s Environmental footprint developments for life cycle related calculations is also well put (while it is not always clear that a carbon footprint is part of the Environmental footprint (EF) set of indicators and - if used - should be calculated with the EF method). As to recycled content and recycling rates as possible elements in specific policies: it is important to be aware that for materials where a bigger share of the material on the market is recycled materials of high quality (and hence available at a market price about equal to that of the primary material), it has no environmental benefit to set minimum recycled content requirements: such will not lead to higher circularity, but only shift the use of the available recycled material from non-regulated products to the regulated products. That situation applies e.g. to most metals, glass, and mostly to paper and cardboard/corrugated board fibres, many pre-consumer plastics. Requiring a minimum recycled content is in contrast environmentally beneficial where little high quality recycled material is available (e.g. fibres/textiles, post-consumer plastics other than PET bottles) or the applications are missing/limited, such as for ceramics, rubber. Here, the requirement of minimum recycled content will lead to increasing prices, potentially also above the primary price, what is resulting in making formerly uneconomic recycling viable; note that this only works if the previously available recycled material amounts are small enough compared to the policy-mandated use. This would also lead to the development of new recycling technologies and new uses for those formerly unused/unusable wastes. The EN 45555 and EN 45557 standards (developed under the Ecodesign mandate) provide an however only partially usable guidance on these two aspects: they miss the specific environmental benefits that hugely differ among materials: the standard only sums up the masses, i.e. recycling of the concrete counterweight of a washing machine is according to the EN 45555 many times better than recycling all copper wires, steel casing, the electronics’ precious metals and rare earth from the rest of the machine, what makes no sense. An approach how to overcome/improve this is referenced in the Informative Annex of EN 45555 that should be explored. Generally, next to the above recommendations, it is advised to always have a dedicated LCA/EF study done to evaluate the recycling efforts and possible downsides of requiring more recycled materials, e.g. resulting sometimes in heavier parts that cause extra environmental burden from extra fuel consumption if used in mobile applications, and other unwanted and overall net negative consequences the requirements can otherwise have. About maki Consulting: maki Consulting GmbH is a small life cycle expert consulting firm, established by Dr.-Ing. Marc-Andree Wolf and Kirana (Chomkhamsri) Wolf. Marc and Kirana have over 20 years’, respectively 15 years’ working experience in LCA and related areas in government (both at the European Commission, Kirana also at Thai NSTDA), at consulting companies, and in research. During our work at the Commission‘s JRC, we have technically lead the original developments of the Commissions ILCD Handbook on LCA and the Environmental footprint method. maki offers strategic LCA and environmental footprint advice, social LCA, method development and evaluation, review, policy impact assessment, data development, and capacity building. Our clients are governmental bodies (European Commission services, national governmental bodies), international industry associations, companies, and other consultants.
Read full response

Response to Environmental, social and governance (ESG) ratings and sustainability risks in credit ratings

6 Jun 2022

maki Consulting sees improving the reliability and comparability of ESG ratings as a highly relevant aim at EU level (and beyond), given the complete lack of comparability and the heterogeneity of the reliability of the ratings. We want to highlight two aspects, one of which that plays a smaller role so far (life cycle perspective beyond carbon) and the second that is almost entirely forgotten in the related discussion (products need to be compared based on their functions). The Commission or its policy IA contractors are invited to follow up with us on our consultation input, to have a (free) explanative call; we have worked in policy IA ourselves. Our two points: Beyond carbon: Even if Life Cycle Assessment (LCA) (e.g. the Commission’s Environmental Footprint (EF) method) are used, and this avoids the shifting of burdens among different parts of the products’ life cycles (i.e. emissions during production vs. during use vs. during end-of-life treatment of products), in ESG this stops usually at carbon / global warming. This ignores that the measures taken (i.e. investments) will lead to a substantial shifting of problems and to plain wrong decision support in a large number of cases: a broader coverage is key to avoid this, e.g. help avoid shifting or burdens also among environmental impacts (e.g. between climate change and land use, as in the case of bioenergy). On functions of products: In the efforts around the EU Taxonomy, industries and products have been classified as good or bad for the environment, based on how many emissions they cause and the room for reduction. This lacks the key insight that a good/better product is one that fulfils the specific need (say: protein for human consumption, footwear for wet weather, …) in the best available way. If this needs materials that have a high environmental impact during their production(!), they may still be the best, if also considering their use (e.g. durability, energy consumption) and end-of-life (e.g. easy to recycle). This understanding means for companies: ESG ratings need to judge the companies by combining the product portfolio’s functional units and the environmental impact of the life cycle of all their products. This may sound like a daunting task, but the Commission’s OEF is (partly) doing this, while it lacks yet the comparison that considers the combined quantified functional units of all the products, weighing those functions by their value for humans (e.g. food and shelter much higher than outdoor patio heating). The OEF so far compares, overly simplified, companies of the same sector by their average impact. The result can hence be improved by the company by portfolio optimization (getting rid of the more impacting ones), while the true environmental impact is not reduced. We note that this approach is still better than most E(SG) ratings we have seen, and in any case would be the best available starting point for ESG ratings and could form the core component of the "E" in ESG, after the sketched adjustments. About maki Consulting: maki Consulting GmbH is a small life cycle expert consulting firm, established by Dr.-Ing. Marc-Andree Wolf and Kirana (Chomkhamsri) Wolf. Marc and Kirana have over 20 years’, respectively 15 years’ working experience in LCA and related areas in government (both at the European Commission, Kirana also at Thai NSTDA), at consulting companies, and in research. During our work at the Commission‘s JRC, we have technically lead the original developments of the Commissions ILCD Handbook on LCA and the Environmental footprint method. maki offers strategic LCA and environmental footprint advice, social LCA, method development and evaluation, review, policy impact assessment, data development, and capacity building. Our clients are governmental bodies (European Commission services, national governmental bodies), international industry associations, companies, and other consultants.
Read full response

Response to Integrated Nutrient Management Action Plan

26 Apr 2022

A coordinated, integrated nutrient management plan is a very welcome, overdue framework to align existing and future policies to improve the overall performance of the agricultural sector, while considering non-agriculture N and P sources and losses as well. In order to be as directionally reliable as possible, we want to highlight here some aspects that are in the current debate not fully appreciated but need to be at the core of the plan: Explicitly and quantitatively consider interrelationship with environmental impacts, foremost land use (occupation and transformation, both directly and indirectly), but also others. Avoid shortcuts and simplifications, for example do not require crop-unspecific fertiliser reduction targets (as relative losses differ hugely by crop). Ensure that yield reductions due to lower amount of applied N fertiliser are fully considered. E.g. organic agriculture has substantially lower yields (between -10 and -50%, especially high for mass products such as grains), among others caused by lower fertilisation levels. Such reduced yield has critical consequences: less harvest means that more natural ecosystems have to be converted to farmland, as the demand for agricultural products is as it is. These natural ecosystems to be lost would be mostly outside Europe, as conversion of European forests to agriculture is argued to see even stronger rejection from citizen than already. In other words: more organic agriculture in Europe leads to more deforestation in the tropics. A general push for organic agriculture would hence be wrong (noting that similar N losses can be achieved in conventional and organic agriculture). As to biodiversity: While it is surely good to have more biodiversity in organic farmland compared to conventional farmland, the extra species that occur are rarely threatened, while those lost in the converted forests are. Take a life cycle perspective of measures and effects, using the Commission’s Product Environmental Footprint (PEF) approach, but also – for consequential analysis and indirect land use effects – the Commission’s 2010 ILCD Handbook, General guidance. Recommendation: The explicit aim of the integrated nutrient management plan for agriculture should be to define and promote overall environmentally optimised farming systems (in life cycle perspective) that consider yield, N and P species emissions and related eutrophication impacts, impact of fertiliser production and management, land occupation and conversion (direct and indirect), biodiversity and ecosystem stability, as well as climate change and other impacts. Such new, sustainable farming systems should take the best from both conventional and organic agriculture. Such would include synthetic and organic fertiliser in improved application schemes (i.e. not in autumn after harvest or too early before spring sowing, injecting manure and not spreading or putting on soil surface), some pesticides (while less substances and less amounts) and/or optimised biological pest control (possibly with some financial incentives), optimised other management measures - differentiated per crop, region and even site (e.g. erosion control, soil structure improvement). More research into biological pest control might be warranted, and finance or other incentives for extended manure storage at farms and for manure injection machines. The rest of the economy would contribute, particularly waste water treatment plants, that should recover more nutrients, sanitize the sludge and bring to agricultural land, while removing/preventing pollutants, particularly heavy metals to be spread to the land. maki Consulting GmbH is a small life cycle expert consulting firm of Dr.-Ing. Marc-Andree Wolf and Kirana (Chomkhamsri) Wolf. Marc and Kirana have over 20 years’, respectively 15 years’ working experience in LCA, PEF and related areas in government (both at the European Commission, Kirana also at Thai NSTDA), at consulting companies, and in research.
Read full response

Response to 2022 Strategic Foresight Report

17 Mar 2022

A Strategic Foresight report on the key synergies and tension points between the green and digital transitions is a highly relevant Communication, to early-on steer developments. We want to highlight a tension point of utmost relevance that has been yet almost entirely overlooked, where digitalisation has severely negative effects on the green transition: Digitalisation is widely seen in industry and governments (and large parts of society) as facilitator of “greening”. However, all this looks at the product/production perspective. Even if life cycle based methods (Life Cycle Assessment (LCA) and the Commission’s Environmental Footprint (EF) method) are used and – importantly – help avoid shifting or burdens among environmental impacts (e.g. between climate change and land use, as in the case of bioenergy) and among different parts of the products’ life cycles (i.e. emissions during production vs. during use vs. during end-of-life treatment of digital devices), the perspective is effectively always a product/production perspective, also in studies labelled green “consumption”. What so far is only vaguely captured, is the net consumption perspective: with increased human productivity – substantially aided by digital products – the European and global product output is ever increasing. Salaries of the employees are used by them to purchase ever more of those products we all produce: increased productivity is fully countering improvements of producing greener products, as more green products still increase absolute impacts. You can read more about this in this book chapter (free access): “From sustainable production to sustainable consumption”: https://www.springerprofessional.de/from-sustainable-production-to-sustainable-consumption/4832140?fulltextView=true . To give a concrete example: while videoconferencing of staff avoids person-travel, it saves also time of the staff: the person can work more and produce more goods, what can more than compensate the avoided environmental impacts of not traveling. What can be done: growth of product output (and hence a key basis of society’s economic wellbeing) needs to be steered – by regulation, financing, communication-efforts and education, and/or aided by research efforts – to meet the needs of all us consumers overall at a reduced environmental impact on a NET basis. Any additional available income and time (and partly space) will inevitably be used by us consumers. Defining and choosing /promoting suitable lifestyles (i.e. a behavioural choice) is an effective approach, IF including explicitly the effects of meeting one’s needs on available income, time and space to avoid unwanted shifting to other consumption. Qualitative growth on society level is another metric that – if operationalised considering the mentioned effects on available household resources – can help steering the transition to an actual green economy. Otherwise: If digital transformation equally aids more production as it aids greener products, the net progress will be zero and a net carbon-neutral 2050 will be impossible to achieve. About maki Consulting: maki Consulting GmbH is a small life cycle expert consulting firm, established by Dr.-Ing. Marc-Andree Wolf and Kirana (Chomkhamsri) Wolf. Marc and Kirana have over 20 years’, respectively 15 years’ working experience in LCA and related areas in government (both at the European Commission, Kirana also at Thai NSTDA), at consulting companies, and in research. During our work at the Commission‘s JRC, we have technically lead the original developments of the Commissions ILCD Handbook on LCA and the Environmental footprint method. maki offers strategic LCA and environmental footprint advice, method development and evaluation, review, policy impact assessment, data development, and capacity building. Our clients are governmental bodies (European Commission services, national governmental bodies), international industry associations, companies, and other consultants.
Read full response

Response to Sustainable Products Initiative

16 Nov 2020

We welcome the potentially far reaching and inspiring approach of a complete overhaul of the Ecodesign Directive, substantially deepening and broadening it. The Ecodesign Directive has very substantially helped to improve the environmental performance of a range of important energy-using (and to some extend energy-related) products on the EU market. This, despite being based on mostly inconsistent and not well documented life cycle data in its original EcoReport tool. This success was possible due to the sole dominance of energy consumption during use, combined with the smart Least Life Cycle Cost (LLCC) basis. Expansion to other products however will require an entirely different approach to data quality and consistency, among other changes on many levels. We support, as sketched in the roadmap, to build the further development method and tool(s) on the Commission’s Environmental Footprint development (after solving some technical and method issues it currently has). We hope that our reflections and suggestions - that systematically go one by one along the many facets of the roadmap - may help the EC services to propose a set of robust policy options for the next step. Please see our attached recommendation.
Read full response