On behalf of Vinventions, CE Delft and Sevenster Environmental
have reviewed the final draft Product Environmental Footprint Category Rules (PEFCR) for wine (version 04) on one specific aspect: the compulsory inclusion of biogenic carbon sequestration in vegetation and soil as additional information in PEF reports for wine and the methodology to be applied for determining the amount of carbon sequestered.
We conclude that this methodology contains several flaws, with respect to both the LCA methodology and scientific calculation rules laid down in the report::
- Temporary carbon storage in vegetation cannot be included in the PEF, not even under additional information. It should hence be excluded from the PEFCFR.
- For carbon sequestration a clear time boundary between temporary storage and permanent sequestration needs to be defined, representative and uniform for all product categories falling under PEF policy.
- Allocation has been elaborated in a negligent way in the draft PEFCR.
- The prescribed calculation methodology based on the Hénin-Dupuis model is not substantiated, has been included with errors, is incomplete (lacks land management factor P, erosion) and is included without a proper guide for background information and calibration.
- The two other prescribed calculation methodologies for calculating carbon sequestration in soil and vegetation are meaningless and erroneous, as the issue time frame is dealt with unsatisfactorily.