A Commentary on "System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2" by Heijungs, R., Allacker, K., Benetto, E., Brandão, M., Guinée, J., Schaubroeck, S., et al. (2021). Front. Sustain. 2:692055. doi: 10.3389/frsus.2021.692055DFG, 414044773, Open Access Publizieren 2021 - 2022 / Technische Universität Berli

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Commentary: System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2

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GENERAL COMMENTARYpublished: 30 August 2021doi: 10.3389/frsus.2021.729267Frontiers in Sustainability | www.frontiersin.org 1 August 2021 | Volume 2 | Article 729267Edited and reviewed by:Mikołaj Owsianiak,Technical University ofDenmark, DenmarkMélanie Douziech,MINES ParisTech, PSLUniversity, France*Correspondence:Matthias Finkbeinermatthias.finkbeiner@tu-berlin.deSpecialty section:This article was submitted toQuantitative SustainabilityAssessment,a section of the journalFrontiers in SustainabilityReceived: 22 June 2021Accepted: 06 August 2021Published: 30 August 2021Citation:Finkbeiner M (2021) Commentary:System Expansion and Substitution inLCA: A Lost Opportunity of ISO 14044Amendment 2.Front. Sustain. 2:729267.doi: 10.3389/frsus.2021.729267Commentary: System Expansion andSubstitution in LCA: A LostOpportunity of ISO 14044Amendment 2Matthias Finkbeiner*Chair of Sustainable Engineering, Institute of Environmental Technology, Technische Universitaet Berlin, Berlin, GermanyKeywords: ISO 14044, LCA, life cycle assessment, allocation, system expansionA Commentary onSystem Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2by Heijungs, R., Allacker, K., Benetto, E., Brandão, M., Guinée, J., Schaubroeck, S., et al. (2021). Front.Sustain. 2:692055. doi: 10.3389/frsus.2021.692055INTRODUCTIONHeijungs published recently together with seven co-authors an opinion paper in this journal titled“System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2”(Heijungs et al., 2021). Their contribution makes mainly two points:• According to their interpretation, the 2nd amendment of ISO 14044 (ISO 14044, 2020)“effectively rules out [actual system expansion and] prescribes that expanding the system toinclude additional functions must be understood as subtracting avoided burdens with thesubstitution method.”• The amendment has failed to bring the clarification, that “the LCA community has been eagerlylooking forward to [. . . ] to a largely confusing hierarchy to address themulti-functionality issue.”This reply intends to clarify, that the first of these points is based on an erroneous interpretation ofthe standard, respectively, amendment and that the second point is based on a misunderstandingof the global, stakeholder-oriented standardization process at ISO.INTERPRETATION OF ISO 14044 AMENDMENT 2The proper interpretation of International Standards (ISO) requires an understanding of thespecific language and coding rules, which apply to them. While they are ideally as understandableas possible for as many stakeholders as possible, a certain knowledge of the standard language andrules is necessary to decipher them correctly. While these codes and norms may appear to some assuperfluous and misleading at first sight, they have the same justification as other formal codes likee.g., mathematics, legislative language, or the language of certificates of employment. Languagesin such contexts may appear also difficult to understand at first sight. As a consequence, they aresometimes not interpreted correctly, especially when taken literally, while they are crystal-clear forthose in the know.The first main conclusion of Heijungs et al., i.e., the interpretation of the Amendment 2as being prescriptive for only allowing system expansion as substitution (avoided burden) andFinkbeiner Commentary: Interpreting ISO 14044 Amendment 2 Correctlytherefore restricting what they call “actual system expansion”is based on the following text in the standard: “Therefore,the product system that is substituted by the co-product isintegrated in the product system under study. In practice,the co-products are compared to other substitutable products,and the environmental burdens associated with the substitutedproduct(s) are subtracted from the product system understudy.” It is correct, that basically this whole section focusseson this particular option for system expansion. When takenseparately and when read as colloquial language, this may leadto the impression of Heijungs et al., but there are severalstandardization aspects that make it crystal-clear, that such aninterpretation is not correct:1. An amendment has to be read together with the main body ofthe standard (ISO 14044, 2006). It does not replace the contentof the amended standard, it adds to it. Therefore, as Heijungset al. point out by themselves, the generic system expansionclauses are introduced in the beginning of the amendment.They are still valid and the amendment just adds to it, it doesnot replace it.2. ISO has in their Directives clear rules, that certain verbalexpressions have to be used to identify the normative contentof the standard, i.e., “shall” for requirements, “should” forrecommendations, “may” for permissions and “can” forpossibilities (ISO, 2021a). The text referred to by Heijungset al. does not include any of these verbal forms, i.e., it cannever have any binding meaning or even overrule the “shalls”and “shoulds” in the main body of the text. It is purely adescription, that is not normative at all.3. The Amendment is an informative Annex. If an Annex isqualified in the heading as “informative,” this is an obviousindication, that its clauses (here: the Amendment) cannotbe interpreted in changing any of the existing requirementsof the associated standard (here: ISO 14044). Annexes areused to provide additional information to the main bodyof the document, e.g., by presenting information regardinga particular application of the document. There are alsonormative annexes, which provide additional normative textto the main body of the document, but informative annexes—as the one relevant here—are not normative at all. As such,an informative annex can never change the actual content orinterpretation of the standard.The actual intention of these clauses in the amendment wasthe consensus, that it should be clarified, that the “subtractionapproach” can also be used as system expansion as is commonlydone in LCA practice. This was always the intention as originallydocumented by ISO 14041 (1998) as Heijungs et al. pointout as well. However, recently there were some scholars fromthe academic world, who were arguing that the “subtractionapproach” is not covered by system expansion according ISO orthat system expansion altogether would only belong to particulartypes of LCA. Therefore, the amendment clarifies, that systemexpansion is applicable for all types of LCA and that the“subtraction approach” is covered by the requirements for systemexpansion in ISO 14044.It was never the intention to make it the only option, it was theintention to clarify, that it is one of the options. This is properlyreflected by the text of the amendment, if the standardizationrules and language are considered. In a nutshell, the allocationannex of Amendment 2 did not include any changes to therequirements and recommendations of ISO 14044 when it comesto allocation as this is not possible by an informative annex—per definition. As such, contrary to their interpretation, theAmendment 2 fully satisfies the request of Heijungs et al. to haveboth options for dealing with system expansion.For the second topic, “the lost opportunity” for clarificationof the multi-functionality issue, there is a commonmisunderstanding about the international standardizationprocess. Standards are sometimes criticized by some stakeholders(especially from academia) for not being specific enoughon certain issues. There are some scholars with strongconvictions in certain topics, even though they are valuechoices, like e.g., allocation. They typically come from a rathertheoretical background.There is the famous quote of unclear source: “In theory there isno difference between theory and practice, while in practice thereis.” Standards are for practice, not for academic theory. Theyrepresent the global consensus on those methodological featuresfor which such a consensus exists. More specific stipulations on,e.g., allocation procedures or a default set of impact categories, letalone a particular impact assessment method might be desired bysome stakeholders, but there is no global stakeholder consensuson them. It is a very democratic procedure to develop an ISOstandard, but democracy does not guarantee that the outcome isto the liking of everyone. Standards do not have specific authors,they are collaboratively written by often hundreds of people,who provide comments as member of the working groups or asmember of the national mirror committees that provide inputto the standard development. It makes no sense to blame thestandards or those involved in the standardization process forthis, as it is the natural result of such a process, that there is no“a one size fits all-LCA” and that the final text is a compromise.ISO standards respond to a need in the market (Finkbeiner,2014). While academic debates are dominated by the providersof LCA, standards need to focus on the users of LCA. WhileHeijungs et al. qualify the ISO hierarchy for multi-functionalprocesses as “largely confusing,” many users seem to be able towork with this hierarchy without any show-stopping problems.Many users identified proper ways, how they handle this withintheir sector or for their products. At least, it was not confusingenough for them to agree on a change of this hierarchy.ISO standards are based on global expert opinion (Finkbeiner,2014). ISO standards are developed by groups of experts fromall over the world and standards should not target the 5%most advanced users, but the whole world. As such, while someleading experts in the developed world may feel, it is time, thattheir ideas are reflected in a standard, many other parts of theworld may have just started to understand and implement themore established practice documented in the standard. Whileestablished practice starts to get traction, they are not keen toswitch to the latest trend in LCA science immediately.Frontiers in Sustainability | www.frontiersin.org 2 August 2021 | Volume 2 | Article 729267Finkbeiner Commentary: Interpreting ISO 14044 Amendment 2 CorrectlyISO standards are developed through a multi-stakeholderprocess and ISO standards are based on a consensus (Finkbeiner,2014). This means, they are not primarily about beingtheoretically right and academically advanced. They are acompromise of a democratic consensus building process and notabout academic dogmatism.CONCLUSIONThe take-home message of this reply for LCA practitioners is,that they can still do system expansion according to ISO 14044both ways—by adding additional functions or by subtractingadditional functions. The interpretation by Heijungs et al. thatAmendment 2 is supposed to restrict the use of “actual systemexpansion” in any way is a misunderstanding and thereforenot correct.Anyone envisioning future revisions of ISO 14044 cancontribute to the process, but understanding the standardizationprocess and its rules is important to manage expectations.Standards are not necessarily about academic excellence.According to ISO (2021b), “standards are the distilled wisdomof people with expertise in their subject matter and who knowthe needs of the organizations they represent—people suchas manufacturers, sellers, buyers, customers, trade associations,users or regulators.” While it is acknowledged that somerespected academic colleagues see the completed Amendment 2as a “lost opportunity,” the actual target audience of the standardsis apparently of a different opinion as the amendment wasapproved almost unanimously with 93% positive votes.AUTHOR CONTRIBUTIONSMF drafted and edited the text.FUNDINGThere was no third-party funding provided for this paper, butthe support by the Open Access Publication Fund of TU Berlinis acknowledged.REFERENCESFinkbeiner, M. (2014). “The international standards as the constitution of lifecycle assessment: the ISO 14040 series and its offspring,” in Background andFuture Prospects in Life Cycle Assessment. LCA Compendium – The CompleteWorld of Life Cycle Assessment, ed W. Klöpffer (Dordrecht: Springer), 85–106.doi: 10.1007/978-94-017-8697-3_3Heijungs, R., Allacker, K., Benetto, E., Brandão, M., Guinée, J., Schaubroeck,S., et al. (2021). System expansion and substitution in LCA: a lostopportunity of ISO 14044 Amendment 2. Front. Sustain. 2:692055.doi: 10.3389/frsus.2021.692055ISO (2021a). ISO/IEC Directives, Part 2, Principles and Rules for the Structureand Drafting of ISO and IEC Documents. 9th edn. Geneva: InternationalOrganization for Standardization.ISO (2021b): Standards. Available online at: https://www.iso.org/standards.html(accessed June 22, 2021)ISO 14041 (1998). Environmental Management. Life Cycle Assessment. Goaland Scope Definition and Inventory Analysis. 1st edn. Geneva: InternationalOrganization for Standardization.ISO 14044 (2006). Environmental Management. Life Cycle Assessment.Requirements and Guidelines. 1st edn. Geneva: International Organizationfor Standardization.ISO 14044 (2020). Environmental Management. Life Cycle Assessment.Requirements and GuiISOdelines. Amendment 2. Geneva: InternationalOrganization for Standardization.Conflict of Interest: The author declares that the research was conducted in theabsence of any commercial or financial relationships that could be construed as apotential conflict of interest.Publisher’s Note: All claims expressed in this article are solely those of the authorsand do not necessarily represent those of their affiliated organizations, or those ofthe publisher, the editors and the reviewers. Any product that may be evaluated inthis article, or claim that may be made by its manufacturer, is not guaranteed orendorsed by the publisher.Copyright © 2021 Finkbeiner. This is an open-access article distributed underthe terms of the Creative Commons Attribution License (CC BY). The use,distribution or reproduction in other forums is permitted, provided the originalauthor(s) and the copyright owner(s) are credited and that the original publicationin this journal is cited, in accordance with accepted academic practice. Nouse, distribution or reproduction is permitted which does not comply with theseterms.Frontiers in Sustainability | www.frontiersin.org 3 August 2021 | Volume 2 | Article 729267

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Commentary: System Expansion and Substitution in LCA: A Lost Opportunity of ISO 14044 Amendment 2

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