December 2, 2021
As more eyewear floods the market, brands, manufacturers and retailers have the opportunity to differentiate their products by evaluating and verifying their sustainability attributes.
In particular, the luxury and fashion eyewear industry focuses on the sustainability of its practices and therefore needs to consider its supply chain during design and materials selection phases.
Following UL’s webinar “Eyewear: Set Your Sights on Safety, Quality and Sustainability,” we interviewed our sustainability expert Maria José Monteagudo Arrebola to delve into topics like recycled and reused materials, the regulatory landscape for green claims and the documentation you should request from your suppliers.
Question: When do you consider a material reused and not recycled?
Maria: If we attend to the definition of pre-consumer recycled material given by ISO 14021, the reclaimed material has to be classified as waste and discarded from the processes that have generated it. Recycling procedures include some sort of physical/chemical processes to be able to use the reclaimed material with a new purpose. If we take scraps from a production line, regrind them and then put this material back into the production line, then we are talking about reused — not recycled — material. A really good document that can shed light on these aspects with examples is UL’s white paper on interpreting pre-consumer recycled content claims.
Question: What actions are governments taking to improve the value and effectiveness of green claims?
Maria: There are four main areas:
- Consumer education
- Environmental claims guides
- Mandated environmental labeling requirements
- Legal action and enforcement
It is important to highlight that many governments can take action on environmental claims under existing general false advertising laws or under specific rules that apply to particular claims.
Depending on the jurisdiction, penalties for false claims, including green claims, might include criminal convictions and fines, infringement notices, and injunctions. An example of this is related to Europe, as there is no European legislation that specifically harmonizes environmental marketing, but it is covered by specific community legislations as, for example, EU Directive 2005/29/EC, also known as the Unfair Commercial Practices Directive.
Question: In terms of environmental attributes, what kind of documentation should we request from our suppliers?
Maria: You should request any evidence that can prove the environmental attributes of their materials and/or operations — for example, recognized certifications, test reports from accredited laboratories, environmental audit reports, their presence in sustainable material listings, etc.
For UL 2809, the Standard for Environmental Claim Validation Procedure (ECVP) for Recycled Content, you should specifically request documentation on:
- The design of the product and the documentation from the manufacturer or manufactures’ supply chain describing the attributes and source of the recycled material.
- The documentation from the manufacturing process that demonstrates effective control of materials during production is relevant for any type of material.
For UL 9798 ECVP for Biobased Content, we ask for a Test Report to ASTM D6866 that is not more than three years old, because it is the only one removing carbonates prior to going to mass spectroscopy.
How UL can help
With scientific rigor, UL evaluates the validity of specific sustainability attributes you want to share with your final consumers. During UL’s Environmental Claim Validation (ECV), our team assesses recycled and biobased content, recyclability rate, volatile organic compound (VOC) content and more.
In an environment where the rise of greenwashing (conveying misleading or unsubstantiated claims about environmental sustainability) has led to increased consumer skepticism, pursuing Environmental Claim Validation empowers you to talk about your eyewear labels with truth and transparency, affording your customers greater peace of mind.
Contact us to learn more.