📄 Extracted Text (4,627 words)
(Mis)Understanding Green Products
A DIZZYING ARRAY OF GREEN-PRODUCT CERTIFICATION PROTOCOLS ARE OVERWHELMING THE
BUILDING INDUSTRY -EVEN STAUNCH ADVOCATES SEE A TOUGH ROAD AHEAD FOR ARCHITECTS
By Russell Fortineyar
tan Rhode., the president and C.E.O. of Scientific Certification Herman Miller's Celle
systems, or SCS„ certifies building products. He's been doing it chair meets both
since 1984. You bring him carpet you think is sustainable and Cradle to Cradle
hell certify it against the new NSF 140 Sustainable Carpet and Groonguard
Assessment Standard. Bring him anything and he'll likely find a standard. product-cart/math:In
somewhere, to use for certification. There are thousands of standards, requirements.
most of which are accredited by the American National Standards
Institute (ANSI), so Rhodes is in no danger of running out of work.
But today. Rhoda doesn't want to talk about standards or certi-
fication. If you're talking sustainabiliry. Rhodes says, so-called green
building products don't much matter in the scheme of things. "Building
envelopes are only IS percent of the total life-cycle impacts of any build-
ing," he says, sitting in his office in Emeryville, California. For Rhodes,
life-cycle impacts mean energy use, or the carbon footprint. He says the
real question is how you reduce the energy impact of the work function—
that other 85 percent consisting of the people who spend a minimum of it
8 hours of their day sitting in your building, when not commuting—on
the natural environment of your budding and the larger region. lions to take seriously is difficult: complains Melissa Mizell. an intern
That one of the more influential people in the sustainable design architect at Gender's San Francisco office. "You either have to embrace It
world is growing impatient with the mounting army of building products challenge or give up." That sentiment is expressed by many architec
purporting to be "sustainable" should be alarming. But talk to anyone who working in sustainable design, even those supported by in-house sustair
specifies, designs, builds, or certifies green products and you'll hear the ability experts with the resources of a large firm.
same frustration lurking in their voice. "We're trying to balance delivering The design world is discouraged because there is no uniform
what the client wants on schedule and on budget. so adding this other level reliable industry consensus in certifying many green products and, i
of complexity of having to understand what standards and what certifica- this vacuum, organizations and special interests are rushing in with pn
grams and certification labels of sometimes dubious quality. Slap
picture of the earth on anything and. presto, it's earth-friendly. The gree
CONTINUING EDUCATION products jumble might be sustainable design's first internal crisis. An
set /4). /Jr: rheloilinerm/ learning objectives to focus your study you've been warned.
COURTESY HERMAN MILLER INTERNATIONAL
40 4
• while reading this months mu:sanctums *tmp/
1*
•.
MA Continuing Education article. To tarn one AlA The standard raspiness
C.
0 2 learning unit. including one hour ofhealth. inkty. and Standards can come from anywhere. If you can get enough volunte.
whar v min. tune to page 181 and follow the instructions. Other oppor- industry players—manufacturers, trade organizations, governmer
ttttt receive Continuing Education :Wits in this issueam be experts, scientists, environmentalists, architects, and other interested pa
found beginning on page Md. ties—in a room, with a few years and some good luck, you can produce
standard. That's more or less what happened with NSF 140, the sustainab
carpet standard. NSF International is a nonprofit, nongovemment
LEARNING OBJECTIVES organization that provides the umbrella for the development of ANS
. 1,nldtieable to: accredited standards. NSF and the American Society for Testing an
l 'I, 14 ,, • one:,• • 4 , illiCdfil111$ ill the building industry.
Materials (ASTM) arc the two biggest players in the US. standard-makir
2. Explain the surge of new green product labels in the design industry world. Neither organization enforces its standards, nor certifies produc
3. Dewily the difference between first, second-. I:bird-party against standards. They simply ensure that appropriate protocols al
iernlYing followed, that a consensus is reached, and that the standard is publisher
a Dru Meadows. AIA, is a consultant and founder of Tulsa-base
O
For this story and more continung mucaoon, as weft as links to sources. white theGreenTeam, which advises corporations and product manufacturers
a.
a. sustainabiliry. She is also a volunteer on ASTM's sustainable building con
II 0 7 Aft haat gird Reoirilr 17
EFTA00281487
A Brief Guide to Select Green Product Certifications
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. Mil ) I S SFI Mee;
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- - --- -
FSC
FSC Forest Stewardship Energy Star MPI Green Performance SR Sustainable Forestry
SCS Sustainable
Council Certification for Environmental Protection Master Painters Institute, Initiative, American Forest
Choice Scientific
& Paper Association,
ARCHITECTURAL TECHNOLOGY
Forest Management and 49enCh kwAvienergYslat 9° v Certification Systems,
Chain of Custody, Established: 1992 Established: 2005 sinvw.about-stkorg
www.fsc.org Industry: Electronics, Established:2006
Industry: Paint, lacquers, Established: 1996
Established: 1993 appliances, HVAC, building stains, floor coatings, and Industry: Forest products
Industry: Indoor carpet,
Industry: Forest products systems fire retardants About SF I was launched as
other building products
About: FSC is an independ- About: EPA's Energy Star About This standard is a response by the timber
About SCS's Sustainable
ent, nonprofit organization was established to standard, Choice label recognizes car- based on the E PA's stan. industry to the establishment
that sets standards for sus- ize energy efficiency fora pets that conform to the NSF dards for VOC content levels of FSC. It's a third-party
tamable forest management range of products and build- in surface coatings, as well certified standard that yen-
140 standard for sustain-
and accredits thirdiparty inns. Relevance: Energy as those of California's Air fies sustainable logging and
able carpet, but will expand
organizations to certify Star continues to be updated to other industries and stag- Quality Management reforestation. Relevance:
products. Relevance: and is one of the most suc- dards Relevance: SCS is a Districts. Relevance: Green SF I certification is not cur-
FSC is the only sustainable cessful federal government third-party testing and certi- Seal's sustainable paint rently accepted by LE ED,
wood certification recog- programs.The EPA launched fication organization widely standard is based on MPI's although this has been the
nized by the USGBC's LE ED the Watersense program in recognized in the sustainable Green Performance, and it topic of much research and
rating program and has wide 2007 to address water- is recognized in the LE ED discussion in the sustainable
design community for its
industry recognition. saving products. impartial and reliable work. rating system. design community.
crisg.N.9)4Jca posth.mo ii ..,70
---
• # Sidi
Greenguard Cradle to Cradle Planet Positive CRI Green Label Plus Green Seal Green Seal
Greenguard Environmental McDonough Braungart dCarbon8/Battle McCarthy, Carpet & Rug Institute Organization,
Institute WEI), Design Chemistry (MBDC), wvamplanetipositive.org (CRI), www.carpet-rug.org www.greenseaLorg
Www.greenguard.ong Established: 2006 Established:2004 Established: 1989
Established: 2002 Established: 2005 Industry: Products and Industry: Carpet Industry: Building products
Industry: Building products Industry: Any buildings About This label indicates About The nonprofit, indoi
and furniture About MBDC's program AboubdCarbon8 established compliance with California's pendent Green Seal develops
About: GE I is a third-party, uses life-cycle assessment, the program to standardize CHPS Section 01350 for accredited, open standards
nonprofit organization that focusing on recyclability, how carbon credits have been acceptable emissions for based on existing standards,
certifies products for emis- disassembly, and material treated in the building Indus- indoor air quality, also rec- all focused on life-cyCle
signs for indoor air quality. content as chief concerns. try. Products and buildings ognized as the NSF 140 assessment for many
Relevance: The Greenguard Relevance: Cradle to are given credits that must standard for sustainable products. Relevance:
air-quality certification has Cradle has significant be offset by owners. carpet. Green Seal standards are
achieved wide industry industry recognition and is Relevance: Planet Positive Relevance: This label is cited by L EED, as well as
acceptance, from Cradle to considered comprehensive, has lately focused on simply the carpet industry's by government entities.
Cradle to LE ED. It has but its proprietary, closed buildings, since few if any recognition of its sustainable Although it maintains stam
been incorporated into other process and lack of certified products offer the credits. products and, though dards for a limited group of
standards for a variety of products has frustrated the Its U.K. base has limited respected, is still considered products, it is viewed credibly
products. design community. efforts to expand in the U.S. a second-party label. in the market.
Pe..ri,rinAl.On 41010eglin this than was Compiled through a ran! Of sources, including interviews for the accompanying article, Dream recoiling for icor 1ETOM PE corn and
• . •to5ce•ce in.:pilot mlonomion prov icl try the organicaton$ profiled, and from the organizal.ons"ligg sites.
EFTA00281488
mince, which covers products and buildings. There are hundreds of stan- widely known for consumer electronics. This is a voluntary program that
dards on the committee's wish list. For example. there is currently no single-attribute—it basically guarantees a product meets energy-efficient
industrywide, specific standard on what qualifies—the materials, tech- criteria—and it is based on existing standards, rather than being a standar
nique& and pmass—as acceptable rammed-earth construction. That could itself. For example, the Energy Star requirements for a geothermal he.
explain why many clients shy away from such building methods. While their pump are based on standards prepared by the International Organizatio
are many standards in development, including those for rammed earth, for Standardization (ISO). This approach—creating a product label base
there are a few ASTM standards that act as umbrellas for sustainability, such on other standards—is common and partly explains the rash of new grec
as the ASTM E2I 29.05 Standard Practice for Data Collection for product labels. However•architects interested in sustainability often fund d
Sustainahility Assessment of Building Products and ASTM E2432.05 single-attribute label certification to be of limited use. Having an enerj
Standard Guide for General Principles of Susrainability Relative to efficient geothermal heat pump makes sense, but not if that pump is col
Buildings.If you drop a reference to ASTM F2129 into your green specifica- structed of materials that harm the environment. A multi-attribu
tions, you're basically forcing the manufacturers of the products for your certification could address this.
project to comply with a standard set of submittal criteria. This allows man-
ufacturers to compete on an even keel.-E2129 was motivated by frustrated The hand that rocks the cradle
manufacturers who were getting questions from architects such as 'is your In 2007, the most recognizable of the multi-attribute certifications
product green: " says Meadows. "Now the attributes are on an apples-to- McDonough Braungart Design Chemistry's Cradle to Cradle prograr
apples basis. With this market evolving as it is, this is a big accomplishment." which achieved notoriety with the 2002 book, Cradle to Cradle Remakit
Of course, this evolving nature of the green-products market the Way We Make Things. written by William McDonough, FAIR, an
leads to another set of problems. To return to our example of carpet, an Michael Braungan. The idea of making a product that would be endless
architect might ask why you would need a standard that focused specifi- used or reused has been so compelling in the sustainable design indusn
cally on sustainability. After all, shouldn't all carpet be sustainable? Why that "cradle to cradle" has become shorthand for the goals many peop
have two standards? For the most part, this is guided by the industry, and organizations are working toward. It's the Kleenex of sustainab
which needs to fulfill the demands of both nonsustainable and sustainable design. McDonough Braungart, or MBDC, developed the program as
markets. But also by chance, as the State of California, seeking to reduce proprietary standard, so a manufacturer is forced to submit materials I
landfill waste, focused its efforts toward developing a sustainable standard MBDC for evaluation and certification. Cradle to Cradle focuses on tl
since discarded carpet was its biggest landfill culprit (the standard origi- life-cycle of a product, looking at where it is produced, the material
sources, and how it is used after it's no longer needed—all in addition
MEASURING INDOOR AIR QUALITY the product's construction and performance. Although the Cradle
IS A SCIENCE, WHEREAS ACCOUNTING FOR Cradle program, which was officially launched in 2005, is not an accret
Red standard, it is partly based on accredited or consensus standar(
SUSTAINABILITY IS MORE OF AN ART. similar to the way the Energy Star program is structured. While Cradle
limed with yet another party, the independent Institute for Market Cradle is one of the few certification labels that qualifies for a LEE
transformation to Sustainability. or 1MTS, which is a Washington• Innovation point and also satisfies the EPA's Environmentally Preferab
I U:.-bawd mess-market group of concerned manufacturers). Alternately, Products requirements for government purchasing, few manufacture
with -sample of rammed-earth construction, there is no need for a have invested in certification.
specifically -grave standard, since there are, more or less, only a few ways While many in the design industry see Cradle to Cradle as
to do it. Judging a rammed-earth wall's sustainable attributes would be important development, many regret the proprietary nature of the pct
more appropriately handled in a "whole-building" rating system, like the gram—as well as the conflict of interest posed by a manufacturer hirir
U.S. Gram Ititilding Council's LEED program. You could write a book— MBDC as a sustainable product consultant and then paying them to a
and many have-,bout the proper way to evaluate sustainability in a tify its products—and think these issues will limit its effectiveness. But r
building or the components of a system. Meadows says this is one of the one denies that the program, which could apply to anything from a toot)
difficulties of even talking about sustainability standards, since you have to brush to a 747, is one of the most comprehensive on the market.
consider things like the economic and social issues tied to the product, in Paul Murray. director of environmental health and safety
addition to the • ' I aincerns. Measuring an attribute like Michigan-based Herman Miller, has seen a lot of changes in the induct:
indoor air quality is a science, whereas accounting for sustainability is since he started working on environmental issues full-time for the compact
more of an an. "It requires not just a familiarity with the materials and in 1992. Herman Miller—a manufacturer longcommitted to environmen
your systems," she says, "hut a Ian kground in applied ecology, socially tal concerns—was the first company to certify a furniture product• the Mir
responsible investing, or any number of environmental issues: chair, as Cradle to Cradle. "To some degree, it hasn't always been a but
If it's so difficult to coordinate the thousands of players in the degree of cost: Murray says. "Reengineering products to meet Cradle
building industry, why doesn't someone with practically unlimited Cradle has produced some less-expensive features that have been patentabl
resources and authority step in to streamline the process—someone like the So, we try to integrate it as early as possible in the design process." Part
federal government? It certainly isn't missing from the picture. since the what the program doe• is divide materials into good. okay, and bad cat
Department of Energy (DOE) and the Environmental Protection Agency gories, assigning them colors. Green stands for good• red for bad. Put a n
(EPA) both play large roles in shaping the national agenda toward sustain- chemical in your plastic. you might fail to get certified. Herman Miller h
able design, but bureaucracies and a scattershot approach of uncoordinated now embarked on a process of ridding their supply chains of red material
programs also hamper them. It may come as little surprise to know there is A benefit to embracing Cradle to Cradle has been that it practical
no productive "sustainability czar" in this White House, but that may be ensures the products will comply with any other standard. For exampl
what it would take. There are bright spots. By far, the biggest success of the Herman Miller has been testing its products for low emissions of Volati
DOE and EPA is Energy Star. a joint program dating to 1992 that is most Organic Compounds (VOCs) for decades, but now certifies them again
Ito? Anliikaural Record E
EFTA00281489
Shaw Contract Group's
Ecoworx carpet tile is
a Cradle to Cradle
product. (1) Old carpet
Is returned to Shaw's
plant, where h is
(MUM up (2) before
having the backing
and fibers separated.
(3) The backing Is then
melted and turned into
flow pellets. (4) At this
ARCHITECTURAL TECHNOLOGY
point, the backing is
re-formed into new
back material before it
Is extruded and cut (5).
Shaw documents every
carpet installation, so
It can pursue recycling
the material attar use.
(6)The recycled backing
Is then combined with
the recycled nylon to
form new carpet tiles.
In August 2007. Shaw
Introduced a broadloom
version of the carpet
but it will take at least
seven or more years to
reach the point of full
recyclability.
the Greenguard Air Quality standard. This is an ANSI-accredited, consen- and then passes those credits to the end user. Someone purchasing a Zody
sus-based standard provided by the nonprofit Greenguard Environmental chair then must invest in a renewable-energy project that would offset I al
Institute (GEO, which is exclusively affiliated, though independent from, the percent of those emissions credits."You have to keep in mind that this is an
Air Quality Sciences testing lab (AQS). Herman Miller also participated in emerging motet: Battle says. "The key issues are going to he transparency.
the development of another indoor-emissions standard by the Business and accountability, and honesty. so were taking our time to ensure our proto-
Institutional Furniture Manufacturer's Association (BIFNIA)."I don't know cols are rigorous:
which one will shake out in the long run, but both have credibility because MBDC is aware of the chalknge that lies ahead for Cradle to
they are recognized by the USGBC," says Murray. An industry leader. Cradle. In September 2007, MBDC announced a collaborative relation-
Herman Miller has resources to not only push the market toward specific ship with the influential architectural materials sources company
standards, but also to cover the short-term certification bases. Material ConneXion, geared toward helping companies develop more
Not every manufacturer can afford every green label. Michigan- sustainable materials and products. Steve Bolton, MBDC's manager of
based Haworth may be a competitor to Herman Miller in some markets, business development, says they haven't made a decision about turning
but it also shares similarly ambitious environmental goals. Aside from Cradle to Cradle into an open standard that people could certify against
Cradle to Cradle certification for its Zody chair, it also worked with outside of MBDC. "A consensus-based standard is valuable in that you arc
London-based mechanical engineer Guy Battle to achieve a Planet Positive bringing people together to create it, but it could be watered down in the
certification. Battle's open-protocol program, based on the ISO 14025 end because you are trying to make sure anyone can meet it; Bolton says.
standard for environmental labels and declarations, tracks carbon emis- 'All of our criteria are widely accepted in the scientific community and
sions along the supply chain of a product. accounts for them as credits, typically go beyond what is stringent for any authoritative body:
2.74 in lutoutrai Rand 11.07
EFTA00281490
ARCHITECTURAL TECHNOLOGY
The Greenguard air-quality voluntary system. Greenguard is an independent, third-
Standard Includes more than 150.000 party organization that certifies building
certified products from mote than 100 manu- products for the emission of Volatile Organic
facturers, among them (1) Dupont's Conan Compounds. The program is recommended by
line. (2) CertainTeed's SoftTouch duct-wrap the USGBC's LEED, the National Association of
Insulation. (3) Georgia•Pacilic's DensArmor Home Builders' Green Building Guidelines,
Plus abuse-resistant paperless drywall, and and the Green Guide for Health Care, among
(0) Knoll's Dividends Horizon office furniture other sustainable design initiatives.
4
Gat the third party started Initiative (SF1) which is administered by the timber industry. However. SR
Product certifications, expressed with labels, mostly break down in three certifications are undertaken by independent third panics, such as
ways: first party. second party. and third party. First-party certification gen- PriceWaterhouseC_oopers, since standards development is usually separate
erally means the product manufacturer set up and then tested against the from certification. Other third-party programs include the aforementioned
conditions that supposedly qualify the product as green. SC lohnson's new Energy Star and Greenguard, as well as California Gold and Scientific
Greertlist program is an example of a first-party program. as the claims rep- Certification Systems Sustainable Choice and Indoor Advantage Gold.
resent SC Johnson's own investigations of its products based on a system of All of this can get very confusing, very fast. So, let's return to our
its own design. Regardless of the merits of the manufacturer's program— carpet example.If you needle down to the fine print in many of the labels
and to be fair, SC !Anson has a comprehensive environmental policy that and certifications for sustainable carpet. they often rely on only a few real
puts many companies to shame—most architects working in sustainabiliry standards. On the VOC emissions side, the Carpet and Rug Institute
distrust first-party labels. Second-party labels are more of a gray area, since iCRI) based its Green Label Plus on California's Collaborative for High
these are often based on consensus standards established by an industry's Performance Schools ICHPS) Section 01350 requirements for indoor-air-
trade organization. For example, the Carpet and Rug Institute's Green Label quality testing standards. SCS's Indoor Advantage Gold program for
Plus is a second-party label. Third-party labels, on the other hand, often carpet is based on Section 01350. too. The limits for VOC emissions in
come from a range of organizations outside of the industries seeking certi- NSF 140—the broader sustainable carpet standard SCS can certify against
fication. The Forest Stewardship Council (FSC) is a well-known third-party in its Sustainable Choice program—also refer to Section 01350. If you see
certification and label for sustainably managed forests and timber supply a pattern here, it's that three certification programs for carpet all rely, in
chains. LEED recognizes FSC, but doesn't recognize the Sustainable Forestry part. on an emissions standard developed by the State of California for
1711 Arch:trauma Record 1107
EFTA00281491
public projects. While California helped develop NSF 140, it ultimately Georgia-based Greenguard and AQS. sees no sign of consolidation any
felt the standard wasn't stringent enough for emissions, which is why the time soon. "I certainly don't see the government in a leadership role of
state published a revised standard. California Gold. NSF 140 is organized trying to bring this together." Black says."From my perspective, some of
like LEED, with different levels of compliance for Silver, Gold, and the leading programs need to take a proactive step to focus the industry:'
Platinum. Since California Gold is now identical to NSF 140 Platinum, it TheGreenTeam's Meadows agrees. but she thinks market competition will
will be phased out in a year. increasingly come into play."Certifications and labels are products, so you
"There's no question the state has used its purchasing power to have to ask which one has more credibility, is least expensive, and most
motivate change in the marketplace." says Dan Burgoyne. an architect who adaptable," she says."1 wouldn't want to say the only way to do things is
works as the sustainability manager for California's Department of General with ASTM or ISO or LEED because competition is not a bad thing. At
Services. Although Burgoyne knew there were no carpets certified to NSF some point there are going to be clear winners."
140 Platinum months before it went into effect in September 2006. by the Back in California, SCS's Rhodes still considers life-cycle
assessments the missing ingredient in many of these new programs, espe-
time the deadline rolled around, there were close to eight products certified
cially since it allows you to make incremental improvement in larger
and on the nlarlcct."We put a lot of effort into the carpet standard and prob-
ARCHITECTURAL TECHNOLOGY
ably won't be able to put as much into the others:* he says. though he adds issues affecting sustainability. And he doesn't see a "super-label" for green
the state is working with BIFMA on sustainable office furniture and with products on the horizon."When you get to the product level for certifica-
Green Seal on sustainable cleaning standards. NSF 140 has been a good tion, most likely there arc going to be trade-offs. There is no magic green
bullet," Rhodes says, suggesting that creating standards an industry can
model for other standards, Burgoyne says, because it's a multi-attribute stan-
dard that looks at product development, manufacturing, use, and end use. easily meet won't do much to change the effects of global warming."With
a life-cycle assessment, some of these materials just don't cause enough
No find In sight impact to show up. We see industrial standards we don't agree with, we
It's likely the next decade will be tilled with new standards and certifica- have to set our own." With green product certification, that seems to be
tion labels, giving architects little relief. Marilyn Black, founder of something on which everyone can agree.•
' AIA/ARCHITECTURAL RECORD S. A proprietary certification program that focuses on the lifecycle of a
product is known as which!
...RI CONTINUING EDUCATION
a. Environmentally Preferable Products
INSTRUCTIONS b. Energy Sur
a Cradle to Cradle
• Read the article "t MislUnderstanding Green Products" using the d. Cradle to Grave
learning objectives provided.
• Complete the questions below, then fill in your answers on the next page.
S. The first company to certify a furniture product as Cradle to Cradle was
which?
• Fill out and submit the AIA/CES education re ortin form on the ft. Herman Miller
next page or download the form at b. Haworth
to receive one AIA learning unit C. seedcase
QUESTIONS • MBIX
1. The Anwrkan Society for Testing and Materials does which for standards? 7. Architects often distrust firsopartycenification of a product because of which?
a. enforces standards tan industry organization participated in the formation of the standard
b. certifies products against standards b. the product inanufacturer established the standard
a ensures standards are followed C. an independent organization created the standard
d. ensures standards are published according to acceptable guidelines d. the state of California created the standard
2. Inserting a reference to ASTM E2129 into your specifications results in N. An exampk of a nun.industry-developed. independent certification program
which? is which of the following?
a. ensures the result will be a LEED-catified project a Carpet & Rug Institutes Green Label Plus
b. forces manufacturers of products for your project to comply with a b. Forest Stewardship Council
standard set of submittal criteria C. Sustainable Forestry Initiative
C. answers the question.ls sour product green?" d. SC lohnson's Creenlist
O. certifies products against standards
S. Which of the following tracks carbon emissions along the supply chain of a
product. accounts tar them as credits. and passes them to the end user?
3. I he Energy Star program is all except which of the following?
a first-party certification
a. an energy efficiency standard
b. Cradle to Cradle
b. J voluntary program
C. Planet Positive eertification
C. bawd ins existing standards
d. Scientific Certification Systems
d. a guarantee that a product meets energrefficitncv criteria
4. Cieging a product label bawd on other standards explains what 10.Kuildins envelopes impact which percent of the energy use in the total
lifecycleof any building?
phenomenon?
a 85 percent
a. the ereJIIIIII of volunteer industry organizations
b. 60 percent
b. the evolving nature of the green.products market
c.45 percent
c. the rash ol new green prodo. t labels in the market
d. the so-mini of intilitartribute per kluct.cettilication labels d. IS percent
180 InIntel WM/ Reeont II II,
EFTA00281492
ℹ️ Document Details
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ef17962f96672e1573c9d4507a01edcb18082ab6a204f92cbb0b6e9eb1a687a7
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EFTA00281487
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