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 that should be applied when determining the amount of carbon sequestered.
We conclude that the methodology that should be applied when determining the amount of carbon sequestered contains several methodological flaws, both with respect to LCA methodology and with respect to the 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 appointed calculation methodology based on the Hénin-Dupuis model is not substantiated, has been included erroneously and incomplete (land management factor P, erosion) and has been included without a proper guide for background information and calibration.
- The two other appointed calculation methodologies for calculating carbon sequestration in soil and vegetation are meaningless and erroneous as long as the issue time frame has been dealt with unsatisfactory.