PRODUCT

January 2020

Does CFI recognize the use of PEFCR?

In case of coexistence of several PEFCRs, the PCR of the International EPD® System are recognized valid by the Programme Operator Carbon Footprint Italy. Otherwise, PEFCRs can also be accepted, after been evaluated by the Technical-Scientific Committee (TSC) of the CFI.

September 2020

Does the CFP Systematic Approach compels to realise an internal audit? Such activity needs to be realised before the third-party verification?

The CFP SA is outlined in the Annex C of the ISO 14067:2018. The section C.3.4 “Validation of the CFP systematic approach”, specifies that organizations shall conduct “internal CFP systematic approach assessments at planned intervals, to ensure its continuous suitability, adequacy and effectiveness”.

The goal of this is clearly that, through an internal control, the organisation can guarantee that the systematic approach (CFP SA) keeps being able to ensure the expected outcomes.
The internal audit can thus be considered to be a possible strategy to perform such evaluation, but it cannot be considered the only one.
Nevertheless, the interpretation that sees the internal audit as compulsory before the realization of the third-party verification is not by any means acceptable. This interpretation is to be justified through the experience of verification bodies in the environmental management system. In fact, in accordance to the ISO 17021-1, they include as objective of Stage 1 “to evaluate if the internal audits and management reviews are being planned and performed” (section 9.3.1.2.2 g); in addition, it is specified that during Stage 2 the internal audit and management review have to be revised (section 9.3.1.3 e).

Such requirements are not mentioned in the standards that are currently in force for the accreditation of GHG validation/verification activities (ISO 14064-3 e ISO 14065), nor in the generic standard for validation/verification activity as conformity assessment (ISO 17029), nor in the future revision of the ISO 14065. This is due to the fact that all the mentioned activities are intrinsically different from the certification of environmental management systems.

Therefore, in the GHG accreditation system of verification there is no instruction requiring the realization of an internal audit before the third-party verification.

ORGANISATION

March 2020

What is the method accepted by CFI for reporting indirect emissions from up-stream and down-stream transport?

The Programme Operator Carbon Footprint Italy accepts the following options:

  • accounting methodology based on who paid for the transport. In particular, up-stream emissions are emissions from freight services that are paid for by the organization. Whereas, emissions from down-stream transport are emissions from freight services that are due to the first purchasers or other purchasers throughout the supply chain but not paid for by the organization;
  • accounting methodology based on the type of goods transported. Particularly, the procurement of raw materials is defined as up-stream emissions, while the distribution of products by the reporting organization is recognized as down-stream emission

It should be noted that the CFI prefers the second option, this will be confirmed during the next meeting of the Representative Body of the Parties where the revision of the regulation will be discussed, among others.

March 2020

In which category should be reported indirect emissions from transport of third-party processing?

The Program Operator Carbon Footprint Italy suggests to not reporting these emissions within the category 3.1. – Indirect emissions from up-stream transport and distribution for goods, neither in category 3.2 – Indirect emissions from down-stream transport and distribution for goods. Therefore, CFI recommends to account them in a dedicated category: category 3.6 – Indirect emissions from  transport of third-party processing.