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Dairy Product Environmental Footprint: achievements, challenges, and opportunities

© Danish Dairy Board

Alignment with SDGs


Alexander Anton, Hélène Simonin-Rosenheimer European Dairy Association


The Dairy Product Environmental Footprint (PEF) pilot has been driven by the European Dairy Association (EDA) as a major project to understand better about the overall environmental impact of different dairy products in examining a broad array of environmental issues, like climate (GHG emissions) but also water use, land use change, allocation questions and others. 

The framework of the Dairy Product Environmental Footprint pilot was laid out by the European Commission’s DG Environment initiative “Building the Single Market for Green Products”. In 2013, a pilot phase of three years was launched for non-food products, and in 2014 this was extended to 11 food and drink pilots. Namely, in May 2014, the EC approved the pilot to develop Product Environmental Footprint Category Rules (PEFCR) for the dairy sector. Through this initiative on the Single Market for Green Products, the European Commission aimed to harmonise the communication of environmental performances of products for producers and consumers alike. Member States and the private sector were encouraged to test a life cycle assessment (LCA)-based method developed by the European Commission’s Joint Research Centre to measure the environmental performance of products throughout their life cycles.

Thus, EDA and several actors in the dairy and environmental sector joined forces to develop product category rules for the dairy sector to be used in Europe and beyond. They strived as much a possible to ensure that the wide diversity of dairy farming and dairy processing systems would be considered, in order to enable companies and organisations to assess, display and benchmark the environmental performance of products based on a comprehensive assessment of their environmental impacts over their full life cycle. 

This is especially important in the current context, where changes in dietary patterns and the concept of sustainable diets are gaining in importance in the drive towards reducing the food industries climate impacts. The participation of the dairy sector to the PEF project shows how the European dairy sector is continuously working on improving its unique circularity and sustainability and contributing to safeguard environmental resources, while providing healthy nutrition: dairy products, with all their natural nutrients, offer ultimately a resource and carbon efficient way of achieving a balanced diet. 

The project started with assessing existing footprinting methodologies in the dairy sector, proceeded by defining the scope of five subcategories and the impact categories, for then elaborating detailed product environmental footprint category rules for the dairy sector. Testing studies on products have been done by the companies involved. Whereas the pilot does not cover directly communication tools, some were tested along the way. The Dairy Product Environmental Footprint pilot project was also reviewed twice by four reviewers from all around the world, including LCA experts, industry and NGOs, and finally received full support of the European Commission and Member States in the PEF Steering Committee on 19 April 2018. At the moment, the project is entering a legislative reflection phase, with the European Commission considering some form of transition to be implemented by 2020. 

The PEFCR in a nutshell

This PEFCR covers the full life cycle (“cradle to grave”) for dairy products sold on the European and European Free Trade Association (EFTA) market. More specifically, it includes seven life cycle stages – (1) Raw milk, (2) Dairy processing, (3) Non-dairy ingredients supply, (4) Packaging, (5) Distribution, (6) Use and (7) End-of-life – and provides detailed guidance related to the use of primary and secondary data, data quality requirements, allocation rules, impact categories that shall be addressed and further environmental information to be provided when assessing the PEF of dairy products. 

The following subcategories are considered: liquid milk, dried whey products, cheeses, fermented milk products, and butterfat products. These subcategories were defined with the aim to make the complexity of the dairy sector understandable for all types of stakeholders: consumers, producers, retailers, food processors and regulators. Five different representative products – one for each of the product subcategories – are considered in this PEFCR. All representative products are virtual products, and characterise what is potentially sold on the European market, not what is produced within the European Union. This nuance may be significant for products that are more largely exported from, or imported to the EU. Specific non-dairy ingredients added to dairy products are a part of the product Environmental Footprint, but this PEFCR does not provide detailed guidance on them. 

For each of the subcategories included in the Dairy PEFCR, one screening study and at least one supporting study was conducted to test the applicability of the PEFCR on real products, identifying hotspots and the following relevant impact categories: climate change, water resource depletion, freshwater eutrophication, marine eutrophication, freshwater ecotoxicity land use, and acidification. As can be seen, the Dairy PEF methodology looks at several environmental indicators and not only at the carbon/climate one – this allows to give a much broader and more complete picture one the reality as well as highlight improvements done in the chain. 

On this basis, a benchmark is calculated for each subcategory. Since no detailed market study on dairy products exists at the EU level, the benchmarks were assumed to be corresponding to the representative products defined in the screening study. While we do not question, as a matter of principle, the merits of a benchmark approach as a tool among others to enable final consumers to assess the Environmental Footprint of products placed on the market, we still identify several limitations. At the current stage of development of the PEF methodology, a mandatory and stringent benchmark approach would be premature, and its immediate implementation might give an inaccurate perception to consumers and a wrong incentive to the industry, at least for some of the subcategories. 

Relationship with IDF Guidelines

The Dairy PEFCR has been prepared in conformance with the International Dairy Federation (IDF) guide to standard life cycle assessment methodology for the dairy sector “A common carbon footprint approach for Dairy”. However, the IDF Guide is not totally aligned with our PEFCR because it does not fully fulfil all mandatory requirements set by the European Commission (e.g. some stages are excluded from the product life cycle or some default impact categories are not included). While the IDF Guide solely focuses on carbon footprint, the Dairy PEFCR covers a wide range of environmental indicators and aims to reflect the diversity of dairy products in the EU. 

The shift to remote learning also applied to Dairy Council of California’s Farm to School program, Mobile Dairy Classroom (MDC). MDC is an assembly that brings the farm experience which includes a live dairy cow to students, teaching them how milk and dairy foods get from the farm to the table and how they contribute to a healthy eating pattern. During the 2020–2021 school year, MDC collaborated to begin innovative virtual field trips, combining the traditional experience of an assembly with a virtual farm tour.

Next Steps

The success of the Dairy PEF pilot attests the European dairy sector’s continuous effort for improving not only its economic performance, but also its long-term sustainability. In this perspective, the relevance of the Dairy PEF on the future of the dairy sector is confirmed by the discussions on the United Nations’ Sustainable Development Goals (SDGs) and global effort of promoting more sustainable consumption and production. The global dairy sector has strengthened the necessary partnerships for achieving a sustainable dairy industry, and under the Global Dairy Agenda for Action it has come together to create the Dairy Sustainability Framework, which acts as a roadmap towards achieving greater sustainability and aligning such initiatives around the world. 

Notwithstanding the significant results already achieved, the Dairy PEF methodology still leaves some room for improvement. Firstly, not all dairy products are covered by this PEFCR. In addition, the default data provided have limited applicability to products or materials imported from outside the EU. Uncertainty also remains on the economic allocation for the slaughterhouse part. Another limitation is that LCA impact categories do not cover all impacts of dairy systems on biodiversity, while livestock production plays an important role on biodiversity. Our approach on biodiversity will hopefully be further improved in the future when international scientific consensus is reached on the topic. Last but not least, there is still a level of uncertainty regarding the future governance of the PEFCRs. The future policy options at EU level are unclear, possibly including the integration of the methodology into the EU Ecolabel and Green Public Procurement, or even the creation of a new instrument on green claims. 

With regard to the possibilities on communication to consumers, the current Dairy PEFCR may only support comparative assertions among dairy products from the same subcategory. At this stage, it is in the first place an internal tool for companies for monitoring the environmental improvements over time and managing impacts associated with the products concerned. It is not meant for comparing dairy products from different subcategories or comparing dairy and non-dairy products, also because relevant aspects of concern, e.g. regarding health, quality, and nutritional value are not included in its scope. 

Nevertheless, the approved Dairy PEF is already a major step in shaping the future of the dairy industry and showing responsibility in working on a wide array of environmental tropics, including biodiversity and deforestation. It is now the reference methodology, and brings the dairy industry and its partners to a new milestone on the proactive approach to positioning dairy as a healthy and sustainable food category.