Gino DiCaro

Carbon labeling program

By Gino DiCaro, VP, Communications

Capitol Update, April 11, 2008 Share this on FacebookTweet thisEmail this to a friend

On April 14, 2008, the Assembly Natural Resources Committee will hear AB 2538 (Ruskin D-Redwood City) which would require the California Air Resources Board (CARB) to develop and implement a carbon labeling program for selected consumer products in the state, as determined by the State Air Resources Board.

Passage of this legislation will add complexity to a manufacturers labeling process in California, and exacerbates the difficult challenge California faces in meeting the greenhouse reduction targets specified with the passage of AB 32.   
 
The complexity for determining accurate and useful labels for products cannot be overstated.  Consumer products include ingredients, parts and packaging materials from all over the world and products are shipped to varying locations for final assembly before they are shipped again to their end markets. A particular product’s carbon content would vary based on where it is being sold.  A product label would need to be updated as component parts change, suppliers change or other circumstances arise that would change the carbon equation of its production, distribution and sale.  Accurate labels that consumers could have any reliance upon would be extremely difficult to develop.  

Additionally, since this bill would create a voluntary program, establishing a standard and methodology for determining whether a product has a lower carbon footprint than the "average comparable product" available in the state is unrealistic. Only data obtained by companies choosing to participate in the labeling program will be available for calculating the "average comparable product" figure, significantly skewing any data and misleads California consumers.    

Lastly, the time and resources being dedicated by CARB to the development and implementation effort of AB 32 is immense. Until CARB has the opportunity to fully develop strategies in the scoping plan, it is premature and unwise to impose a new program on an already stretched staff.

CMTA opposes this legislation, believing that resources should be focused on the most cost-effective solutions to allow for the greatest reductions at the least cost to the state’s economy.

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