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									Discussion Paper

Compulsory carbon footprint labelling
for tourism and travel services?

Vienna, 9 July 2010
Project Contact

Andreas Zotz
respect – Institute for Integrative Tourism and Development

Diefenbachgasse 36/9; A-1150 Vienna

Phone: +43-1-8956245-14

A compulsory carbon label for tourism?

Some distinct tourism services – especially those connected with long-haul air travel – can cause
disproportionately high carbon footprints as compared to everyday consumption products. Tour-
ism and transport have regularly been addressed by media as a contributor to climate change.
However, due to the heterogeneity of figures and messages communicated by different stake-
holders, consumers remain confused and poorly informed about the exact dimensions of climate
impact associated with travel services. The instrument of product carbon footprint labelling is
increasingly receiving attention in various economic sectors as a mean for consumer education
towards climate-friendly purchasing. Also in tourism a compulsory carbon footprint label, based
on internationally agreed calculation standards, could in the long term help consumers develop
a deeper understanding of the dimensions of climate impacts associated with their mobility and
leisure behaviour. This discussion paper sums up viewpoints and notions of different organisations
and looks at some essential questions regarding label design and implementation.

Supported by:
Compulsory carbon footprint labelling for tourism services?

Table of Content

1.             InTroDuCTIon ..................................................................................................................... 4

2.             BACkgrounD on meThoDology ......................................................................................... 5

3.             ProDuCT CArBon fooTPrInT lABellIng: DefInITIon AnD reCenT DeveloPmenTs ........ 5

4.             DIsCussIon: CArBon fooTPrInT lABellIng for TourIsm? ............................................... 6

5.             relevAnCe for PolICy sTrATegIes of The euroPeAn unIon
               AnD nATIonAl governmenTs ............................................................................................. 8

6.             lABel DesIgn ...................................................................................................................... 9

7.             sCoPe of APPlICATIon AnD CAlCulATIon sTAnDArDs ..................................................... 10

8.             ConClusIons AnD ouTlook ............................................................................................. 13

referenCes & fooTnoTes .................................................................................................................. 15

Compulsory carbon footprint labelling for tourism services?

1. InTroDuCTIon

The global tourism industry is a significant contributor to climate change, being responsible for 5 % – 12,5 % of
man-made global warming.1,2 It is forecasted, if no comprehensive emission reduction measures are undertaken,
that the sector’s emissions will grow 2.5-fold by the year 2035.3 Some distinct tourism services – especially those
connected with long-haul air travel – cause disproportionately high carbon footprints on a per capita basis.3 For
instance, a holiday return flight from Europe to the Caribbean will entail climate impacts that considerably exceed
the ‘sustainable carbon budget’ for one person in one year – leaving still unconsidered emissions from other
components such as accommodation and activities at the destination.4 Up until now, there is little evidence that
sustainable consumption is entering into the mainstream tourism market. Even though the proportion of LOHAS
(Lifestyles of Health and Sustainability) travellers has been consistently growing over recent years, this customer
group remains small. Market demand is still dominated by ‘high carbon’ products, including fast transport, short
stays and long-haul destinations.

Tourism and transport had regularly been addressed by media as a contributor to climate change. However, due to
the heterogeneity of figures and messages communicated by the different stakeholders, as well as the lack of emis-
sion calculation standards in the sector, consumers remain confused and poorly informed about the exact dimen-
sions of climate impact associated with travel services. A research report issued by the World Tourism Organization
(UNWTO) suggests that a change of tourism consumption patterns has more emission reduction potential for the
sector than technological measures.3 There is general consensus among tourism stakeholders and policymakers
that consumer awareness on climate change issues needs to be improved.5

A Eurobarometer survey in July 2009 found that a majority of European consumers are concerned about possible
negative environmental impacts of the products they purchase. 72 % of EU citizens think that a label indicating a
product’s carbon footprint should be mandatory in the future.6,7 Even though experience with environmental labels
shows that they do not necessarily trigger more sustainable consumption behaviour8, a mandatory carbon footprint
label for tourism and travel products could bring about the following long-term benefits:

•	 It	would	allow	consumers	to	develop	a	deeper	understanding	about	the	dimensions	of	climate	impacts	associ-
   ated with their mobility and leisure behaviour,

•	 It	would	provide	environmentally	conscious	tourists	with	transparent	product	information	in	order	to	economise	
   on their personal climate responsibility, and

•	 It	would	increase	climate	awareness	among	tourism	businesses	as	they	will	be	required	to	establish	emission	
   reporting systems and / or standardised benchmarks.

Based on the above mentioned situation, Respect conducted a consultation involving NGOs and researchers with
different fields of expertise – such as climate change, tourism, emission calculations, product information and / or
EU environmental law. The consultation aimed at providing a basis of decision whether a legally binding carbon
footprint disclosure for tourism & travel services at EU level is desirable and / or feasible.

Compulsory carbon footprint labelling for tourism services?

2. BACkgrounD on meThoDology

This discussion paper was drafted on the basis of desk research as well as an opinionaire which was send out to
different European environmental and consumer organisations, and researchers in the field of climate change and
tourism. The following experts responded to the request:

•	   Bill	Hemmings	(Transport	&	Environment)
•	   Christian	Baumgartner	(Naturefriends	International)
•	   Paul	Peeters	(NHTV	University	Breda	&	eCLAT,	Expert	Group	on	Climate	Change	and	Tourism)
•	   Stefan	Gössling	(Lund	University	&	eCLAT,	Expert	Group	on	Climate	Change	and	Tourism)
•	   Stephan	Krug	(Viabono	–	umbrella	brand	for	ecological	tourism	in	Germany)
•	   Veronika	Haunold	(EEB,	European	Environmental	Bureau)

This paper sums up different viewpoints and notions on carbon footprint labelling in the context of tourism and travel
services. It does not provide a systematic evaluation on all related literature and/or technical issues. The results
should therefore be seen as a basis of discussion and open for further enhancements.

3. ProDuCT CArBon fooTPrInT lABellIng:
   DefInITIon AnD reCenT DeveloPmenTs

This chapter sums up backgrounds on product carbon footprint labelling in general, as portrayed in a recent study
by the German Öko-Institut on behalf of the European Association for the Co-ordination of Consumer Representa-
tion in Standardisation (ANEC).9

The study finds that the term ‘carbon footprint’ has become tremendously popular over the last few years. As such,
a variety of different CO2 or climate protection labels partly tailored to certain product groups is meanwhile available
at	the	international	level.	(e.	g.	UK,	France,	Germany,	Sweden,	Switzerland,	Japan,	Korea,	Thailand).	It	is	found	
that the main focus of most of these labels is on food, although individual foods seem clearly less relevant to the
climate than other product groups.

So far, definitions and uses of the term ‘product carbon footprint’ differ internationally. To Öko-Institut it seems most
appropriate to draw on the following definition of the PCF Pilot Project Germany: “Product carbon footprint describes
the sum of greenhouse gas emissions accumulated during the full life cycle of a product (good or service) in a
specified application.” In this context, greenhouse gas emissions are understood as all gaseous materials for which
a Global Warming Potential coefficient was defined by the Intergovernmental Panel on Climate Change (IPCC). The
life cycle of a product encompasses the whole value chain – from the acquisition and transportation of raw materials

Compulsory carbon footprint labelling for tourism services?

and primary products over production and distribution to the use, recycling and disposal of the product. The term
“product” is used as a generic term for goods and services. The term Product Carbon Footprinting encompasses
the determination and assessment of one PCF.

Ökö-Institut	finds	further	that,	at	the	moment,	the	standardisation	process	for	the	determination	of	one	PCF	is	still	
ongoing (ISO 14067 “Carbon Footprint of Products”, quantification and communication). Therefore most available
PCFs are done on the basis of PAS 2050:2008 (Public Available Specification “Specification for the assessment of the
life cycle greenhouse gas emissions of goods and services”, a guideline below a British Standard) or in combination
with ISO 14040 / 14044 (LCA) and taking into consideration the Greenhouse Gas Protocol Product/ Supply Chain
Initiative of World Resources Institute (WRI) and World Business Council for Sustainable Development (WBCSD).

4. DIsCussIon: CArBon fooTPrInT
   lABellIng for TourIsm?

This section discusses arguments for and against the instrument of carbon footprint labelling in the context of tour-
ism services. The arguments are based on expert interrogation and / or on related documents / publications.

In a joint position from December 2009, ANEC (European Association for the Co-ordination of Consumer Represen-
tation in Standardisation), BEUC (European Consumer’s Organisation), ECOS (European Environmental Citizen’s
Organisation for Standardisation) and EEB (European Environmental Bureau) take the stance that stand alone
product carbon footprint labels should be avoided as these neglect information on other important environmental
aspects. Instead, climate aspects should be incorporated into other environmental information tools, such as inclu-
sion into an excellence label (commonly known as ‘ecolabels’). Carbon emissions are to form part of the certification
criteria, but should not appear on the product label itself. The joint position refers to unsolved communication and
methodological problems, e. g. difficulties in measuring carbon emissions all along the product lifecycle. It is further
emphasised that environmental product information generally has strong limitations for triggering more sustainable
consumption behaviour. However, it is acknowledged by the above mentioned organisations that for a limited number
of product groups – those where greenhouse gas emissions are particularly relevant in the use phase of the lifecycle
– the carbon footprint could be disclosed. The relevance of carbon footprint labelling for such products should be
identified on a case by case basis following sound feasibility studies including all relevant stakeholders.8

Conclusions from an expert meeting held by the European Commission, DG Environment, on 8 March 2008 share the
stance of ANEC / BEUC / ECOS / EEB that focusing only on carbon footprint information bears a significant risk – that other
important environmental burdens, such as water, soil, biodiversity, can easily be ignored and forgotten. The report states
that in the worst case focusing on carbon alone can actually shift environmental burdens to other impact areas.10

Stefan Gössling from Lund University in Sweden considers air transport as one of the most carbon intense forms of
consumption. He finds that carbon footprint labelling would therefore be an important instrument to build necessary

Compulsory carbon footprint labelling for tourism services?

consumer awareness. Even if it is not likely to lead to a significant change in behaviour, it can help consumers to
understand how problematic tourism can be from a climate change viewpoint and thus increase their support for
climate policy measures. Gössling finds further that mandatory carbon footprint labelling would be the only way for
airlines to reduce their emissions on a competitive basis.11

Paul Peeters from NHTV University Breda comments that there is not much evidence from research that tourists
change behaviour just based on emission information. He finds, however, that a carbon footprint label may first
help tour operators and other businesses to benchmark and reduce their dependability on carbon emissions, and
that subsequently also a social process may start making even tourists reacting to this kind of information if offered
in combination with viable alternatives. For Peeters an important effect to be achieved through a carbon footprint
label is to get tourism businesses competing about their climate performance. To him the implementation could
be staged on basis of the provided label information: First average footprints, based preferably on globally agreed
benchmarks, should be disclosed per company. In a later step, generic footprints could be indicated per product
group and finally be replaced by real carbon footprints per individual product.12

Christian Baumgartner from Naturefriends International argues that tour operators could benefit from a carbon
label, by showing their responsibility and leadership. He suggests the development of a voluntary label as a first step
and preparation for a legally binding instrument – whose implementation will need a longer time. He also underlines
the optional learning effects for the consumers.13

For Bill Hemmings, Policy Officer at Transport & Environment, a carbon footprint label could constitute a helpful
ancillary instrument for increasing product transparency when aviation will be integrated into the European Emis-
sion Trading Scheme (EU-ETS) in the year 2012. However, he believes that such a label will not change airline
behaviour or deter longhaul agents.14

Veronika Haunold, Austrian board member of the European Environmental Bureau (EEB) shares the stance
that carbon footprint labelling would not influence tourists’ consumption patterns in the short-term, however, she
acknowledges that it would be a first step for long-term changes. Haunold points out that it would be important to
decide if a tourism carbon footprint disclosure should be implemented on a voluntary basis – coordinated by the
European Commission – or as a legally binding instrument at EU level.15

Stephan Krug from Viabono – the umbrella brand for ecological tourism in Germany – supports the idea of a com-
pulsory carbon footprint disclosure for travel products. He refers to the benefits that this instrument could bring as
a benchmarking tool for the consumer.16

Compulsory carbon footprint labelling for tourism services?

5. relevAnCe for PolICy sTrATegIes
   of The euroPeAn unIon AnD
   nATIonAl governmenTs

Discussing the introduction of a carbon footprint disclosure label for tourism appears relevant to the following EU

•	 The	European	Union	2020	Vision	for	“smart,	sustainable	and	inclusive	growth”,	within	the	key	area	of	climate	
   change and energy;

•	 The	Sixth	/	Seventh	Environment	Action	Programme	of	the	European	Union,	especially	relating	to	its	provisions	
   – the improvement of the information provided to citizens on climate change and
   – helping citizens to benchmark and to improve their environmental performance;

•	 The	European	Union	Sustainable	Development	Strategy	(EU	SDS),	within	its	defined	key	priority	challenges
   – climate change and clean energy
   – sustainable transport
   –	 sustainable	consumption	&	production;

•	 The	EU	‘20-20-20’	climate	target	(20	%	reduction	in	overall	emissions	compared	to	1990	levels	by	2020;	a	20	%	
   cut in energy consumption through energy efficiency by the year 2020; and a 20 % increase in the share of re-
   newable energy use by the year 2020);

With the adoption of the Lisbon treaty, a clear competence has been set out for the EU to promote and develop its
tourism sector. The policy framework for tourism currently developed by the EU Commissioner for Entrepreneurship
and Industry Antonio Tajani highlights sustainability as one of four priority areas, including the development of an
EU label for the sustainable management of tourism destinations.

The growing interest of carbon footprint labelling on a political level is also reflected by various actions undertaken
on	national	level	among	EU	countries.	By	2008,	at	least	four	Member	States,	Belgium,	France,	UK	and	Germany	
were independently developing methodologies for measuring the carbon footprint of products.10 As the Product
Carbon Footprint World Forum reports, the recent announcement of France to introduce a mandatory environmental
labelling scheme for products in 2011 has raised significant international attention from businesses, governments
and civil society alike. Following up on developments in France is not trivial, given the extent of the scheme and
the number of organisations involved. Recently the French National Assembly decided to postpone starting the
scheme till half a year later and to introduce an experimental phase. This phase should help generating practical
experiences on the implications for international businesses and stakeholders.17

Compulsory carbon footprint labelling for tourism services?

6. lABel DesIgn

This section provides ideas of how a carbon disclosure label for tourism could appear to the consumer by referring
to some recently developed prototypes.

Gössling and Krug propose that the design of a carbon disclosure label for tourism should build upon the already
well established EU energy label (being used for various household appliances). The colour scheme – ranging from
A for most energy efficient appliances to G for the least efficient appliances – has proven to be easily understood
even by people with no previous knowledge of energy and emissions.11,16,18 Also Hemmings takes the stance that
such a label should display a limited number of categories with distinctive colours and be designed in accordance
with other existing emission labels.14

Gössling provides an example how such a colour scheme could be used for holiday packages, which distinguishes
emissions from transport, accommodation and activities. A summary of total GHG emissions is provided together
with a corresponding measure in fuel use, i. e. a unit most people are familiar with. Finally, a short text compares
emissions caused by the respective journey with sustainable emissions per year to allow for comparison.18 (Figure 1)
Peeters emphasizes the importance of absolute emission numbers to be provided next to the colour scheme.12

The umbrella brand for ecological tourism in Germany, Viabono, has introduced a label with similar design for ac-
commodation providers in 2010, together with its partner CO2OL. The label should be developed further as soon
first practical experiences in the field will be available.16 (Figure 2)

Figure 1: Optimized carbon label proposed by Gössling                                Figure 2: Carbon label used by Viabono & CO2OL
(for travel packages)                                                                (for accommodation providers)

               stockholm – Phuket / Thailand
       100 kg CO2      A
       250 kg CO2          B
       500 kg CO2           C
       1000 kg CO2              D
       2000 kg CO2               e                                                     The Viabono hotel CO2 calculator is based on the methodology
                                                                                       developed by CO2OL which has been approved and validated
       4000 kg CO2                   f       f                                         by the DFGE institute. The CO2 footprint of the above mentioned
       > 6000 kg CO2                     g                                             company has been calculated and classified as follows:

  Transport:                                 3000 kg CO2
                                                                                        Category                               * to *** Hotel
  Accomodation:                              1200 kg CO2                               Climate friendly
  Activities:                                 300 kg CO2                                       A                   A       X,YZ kg CO2 / overnight stay

                                                                                                   B               Item                                       CO2
  emissions of                               4500 kg Co2                                            C              Transport                                    xt
  greenhouse gasses:                         ~ 1080 l Fuel                                                D        Building                                     xt
                                                                                                                   Food & Beverage                              xt
                                                                                                           e       Print                                        xt
                                                                                                               f   Cleaning                                     xt
  3500 kg CO2 per human per year can be considered as sustainable global emissi-                                   Miscellaneous                                xt
                                                                                       Climat harmful
  ons, including all consumption, transports, and housing. Emissions from aviation                                 Supplement                                   xt
  cause considerably greater warming than CO2 alone, which is not cosidered here.                                  Total                                  XXXYYZ t

Source: Gössling (in press)18                                                        Source: Adapted from

Compulsory carbon footprint labelling for tourism services?

Another possibility on how to display carbon footprints for round trips is provided by WWF Germany. They distinguish
carbon emissions in the categories transport, accommodation, meals and activities. The label has the form of a
footprint whose size reflects the total amount of greenhouse gases – the bigger the footprint, the bigger the carbon
emissions. An additional text contains the background information on the emission categories.19 (Figure 3)

Figure 3: “Carbon Footprint for Journeys” developed by WWF Germany
Example: 14 days Beach Holiday on Mallorca, 1 Person (including return flight from / to Germany)

  Tourist Climate footprint
  Co2 per Person 1.221 kg:

                                                                              The transport between the place of
                                                                              residence and the destination causes
                                                                              925 kilograms CO2 equivalents whereof
                                                                              916 kilograms can be attributed to the
     Origin / destination transport                                           flight. 13 overnight stays in a 4 star
                                                                              hotel account for 148 kilograms CO2
                                                                              equivalents, and 25 warm meals (full
                                                                              board) for 91 kilograms. Activities at
                  Accommodation                                               the destinations entail emissions of 58
                                                                              kilograms (rental car use 36 kilograms,
                                                                              motorboat excursion 16 kilograms, quad
      Activities at the destination                                           drive 6 kilograms).

Source: Adapted from WWF, 200919

7. sCoPe of APPlICATIon AnD
   CAlCulATIon sTAnDArDs

As Öko-Institut recommends, it is essential to draw up product category rules for developing product carbon foot-
print labels:

          “The main challenge of product carbon footprints meant for communication is to define the whole
          framework in a way that all products belonging to one product group can be calculated in an as much
          as possible defined way to assure the same approach even if the studies are performed by different
          experts. This requires e. g. the same goals, the same system boundaries, the same calculation rules
          and similar data quality for different studies. With a general ISO standard this can not be achieved as it

Compulsory carbon footprint labelling for tourism services?

        only provides generic rules. Therefore it essential for the future that product category rules (PCRs) will
        be developed that ensure a comparable proceeding within one product group. Such PCRs would have
        to be defined and adopted at the European level. Given the many different product groups this will take
        time and needs prioritisation.”9

There is consensus among EU member countries that a harmonised methodology for measuring various product
carbon footprints at EU and / or global level is highly desirable. As such, the use of a harmonised database was
seen by the DG Environment expert meeting on carbon footpring labelling (March 2008) as highly desirable. Har-
monised data and methodology will aid meaningful product comparisons between similar products in different
shops or in different member states. The Commission‘s LCA Platform is aiming to provide a central database of
such information.10

In the context of these recommendations, the introduction of a carbon footprint label for tourism and travel services
will require beforehand an in-depth examination of product category rules. This section discusses the most important
issues relating to system boundaries, calculation rules and data quality.

Tourism includes many different businesses along the value chain which sell their services both individually and
bundled to the consumers. A compulsory carbon footprint disclosure might thus only be politically realisable if all
sub-sectors – such as tour operators, transport providers and / or accommodation services – have equal obligations.
For instance, introducing a mandatory labelling scheme for tour operators only, while airlines and / or hotels would
not be obliged to indicate the carbon footprint, might lead to competitive distortions. It is likely that disadvantaged
stakeholders will politically oppose such a scheme. Peeters refers in this context to recent experiences in the
Netherlands where the introduction of an official standard for calculating carbon footprints from tourism failed due
to the challenge of addressing partially organised trips (e. g. travel packages where the transport component was
not included). To him a possible solution could be an internet tool that displays the full holiday carbon footprint
and allows the various service providers to input their real emissions as far as they are part of a travel package. An
example for such an internet tool is

Furthermore, an evaluation needs to take place on how frameworks for compulsory carbon labelling could be de-
signed concerning the different sizes of tourism businesses and their different abilities to generate the necessary
data. A big tour operator that already has an environmental reporting system in place and that has enough money
and workforce for implementing such a scheme needs to have a different framework than a small niche operator
with limited financial and human resources. It seems worth discussing the use of standardised emission benchmarks
for those businesses that are not able to set up their own reporting systems.

Gössling and Krug find that basically all tourism services should be displayed by a compulsory carbon disclosure
label. The most important sub sectors to them for being shown are transport and accommodation. These sub-sectors
have the best available emission data. Gössling assesses emissions from activities in destinations more difficult to
be measured.11,16

With regard to transport emissions, there are special challenges for measuring the climate impacts from aviation.
Air transport causes other significant greenhouse effects in addition to CO2 – caused for example by contrails and
cirrus clouds.3 There is a long-lasting discussion on how to take these additional climate impacts into account due
to scientific uncertainties and measurement difficulties. Gössling proposes that a compulsory carbon disclosure
scheme should focus in a first step only on CO2 emissions, as otherwise endless discussions may prevent swift

Compulsory carbon footprint labelling for tourism services?

implementation. The additional warming effects could be included in a second step. Gössling finds that even ad-
dressing CO2 only would mean a lot: Air travel is still a huge source of individual emissions on that basis.11 Hem-
mings refers to the EU Emission Trading Scheme, to be introduced for the aviation sector in the year 2012, as a
possible source of standardised emission benchmarks for air transport services. For long-haul flights, he proposes
using average carbon footprints based on average aircraft data.14 For Peeters, such benchmarks could be based on
annual emission reports from airlines whereas data might be delivered according to the different aircraft types in
use, average flying times and occupancy rates. Such a system would give a further incentive to airlines to improve
their operational emission performance.12 As far as accommodation services are concerned, Baumgartner refers
to possible measurement problems due to uncertainties about the electricity supply mix in different countries.13
Hemmings points to challenges in implementing measurement standards for accommodations at foreign destina-
tions, respectively countries outside the European Union.14 An example of emission measurement standards for
accommodation services is provided by Viabono: its carbon footprint label is based upon data from the German
Hotel Association.16

Another possible source of tourism emission data is the not-for-profit organisation Carbon Disclosure Project (CDP).
CDP constitutes a platform for the world’s largest companies to make their corporate emissions publicly available
in a comparable format. The comprehensive repository of corporate emission inventories also includes tourism
businesses	such	as	big	tour	operators	(e.	g.	TUI,	Kuoni)	and	airlines.20

For having a more detailed discussion among tourism stakeholders on calculation standards, Peeters finds it crucial
to decide beforehand about the envisaged purpose of a carbon footprint label for tourism services. If the goal is to
provide consumers with rather basic climate information that allows them identifying those forms of travelling that
are problematic from a carbon emission viewpoint (e. g. long-haul air travel, cruises, certain forms of luxury accom-
modation), the label could be based on generic data which would facilitate implementation. On the other hand, a
label that aims to provide accurate information on every emission spot in order to show performance on efficiency
improvements (e. g. considering seat occupation rates, aircraft routing, food procurement, light bulbs used in hotels)
appears more difficult to be implemented and to be verified by a third party.12

A more detailed discussion should also be held about the geographical application of a compulsory carbon dis-
closure scheme for tourism. An implementation on EU level – ensuring the same obligations for businesses in all
member countries – seems to be most non-discriminatory from a competitive point of view. Tourism is a highly
internationalized economic sector where businesses often operate in several countries simultaneously. Having the
same legal framework for carbon information disclosure might therefore even facilitate implementation for inter-
nationally operating businesses. On the other hand, issues on legal competences between EU and its member
states are likely to prevent a concerted implementation among the whole EU territory. Haunold points out that – if
implementation is envisaged on EU level – the proposed measures need to be in accordance with the EU treaties
and that the Commission has a legal basis for proposing them. To her such measures could probably not be too
detailed, due to the principle of subsidiarity.15 Hemmings finds it important to get first the commitment by a few
national champion governments in order to successfully promote this tool among EU institutions.14

Compulsory carbon footprint labelling for tourism services?

8. ConClusIons AnD ouTlook

The goal of the consultation was to find out whether a public claim for a legally binding carbon footprint disclosure
for tourism and travel services would find support among European environmental and consumer organisations.
Respect has started this initiative as it feels that the travel industry is substantially lagging behind its stated dec-
laration of intent to educate tourists on climate change issues. Amongst other public statements, the industry has
clearly acknowledged this responsibility in the “Davos Declaration on Climate Change and Tourism” in the year
2007. After working more than three years in close dialogue with the tourism industry, Respect and many of its
European partner organisations believe that not much progress on tourism consumer education will be made un-
less some legally binding framework for climate information will be implemented. This discussion paper sums up
relevant positions and background information that were provided by different experts.

Most of the addressed organisations/experts expressed their interest in discussing compulsory carbon footprint
disclosure for tourism and travel services. The degree of participation can be described as moderate. Some organi-
sations referred to a lack of human resources and working time to actively work on this issue at the moment. The
feedback received from participants can be generalised that there seems to be a difference in positions between
consumer organisations (respectively those organisations with expertise on consumer information) and tourism
organisations/researchers. Consumer organisations tend to be opposed to stand alone product carbon footprint
labels, as these bear the risk of neglecting other environmental aspects besides climate change. They propose that
climate aspects should rather be integrated into certification criteria of already existing excellence labels, such as
the EU ecolabel. This position relates to product carbon footprint labelling in general and has not yet been further
investigated for the special context of tourism services. Tourism experts/researchers tend to be in favour of a carbon
footprint label, as they argue that tourism – and thereof especially the air transport component – is an overpropor-
tional contributor to climate change from a per capita point of view. They find it necessary to introduce instruments
that help raising consumer awareness about climate impacts associated with travel services. Even though there is
an unambiguous agreement among all consulted experts that a carbon footprint label is not likely to trigger more
sustainable consumption behaviour in the short term, most of them believe that this instrument will bring about
long-term benefits with regard to product transparency and support for climate policy measures.

Given this difference in positions, it seems at the moment too early to undertake lobbying activities towards a com-
pulsory carbon footprint label for tourism and travel products at EU level. It is recommended to first deepen the
discussion about possible opportunities and threats of carbon footprint labelling in tourism among a wider circle of
experts. The addressed issues in this paper make clear that any prospective lobbying activities must be based on
a thorough technical and organisational preparation. Particularly, there seems to be a need to further assess

•	 how	the	scope	of	application	could	be	framed	with	regards	to	tourism	sub-sectors,	business	size	and	legal	frame-
   works in individual states (subsidiarity)

•	 which	underlying	emission	calculation	standards	could	be	agreed	upon	on	an	international	legal	basis,	and

•	 how	a	tourism	carbon	footprint	label	could	appear	to	the	consumer	(layout	and	design).

Compulsory carbon footprint labelling for tourism services?

Some of the consulted experts suggested a phased approach for implementation. As such, Baumgartner proposed
the development of a voluntary label in a first step in order to gain practical experiences and to prepare for activities
on a political level in a subsequent step. Peeters suggested staging the implementation on basis of the provided
label information itself: first a compulsory carbon disclosure per company, then per product group, and finally per
individual products.

As a way forward, Respect proposes setting up an expert meeting for further discussing the above addressed
key issues. For carrying out possible follow-up activities it is advisable to create a consortium of some committed
organisations with different fields of expertise. It could be envisaged by this consortium to address the European
Commission to provide funding and assistance for respective activities. Respect recommends further creating an
open information platform – e. g. a mailing list or a web forum – in order to share scientific and practical knowledge
on carbon footprint labelling for tourism.

Compulsory carbon footprint labelling for tourism services?

referenCes & fooTnoTes

1	 Scott,	D.,	Peeters,	P.,	Gössling,	S.	(2009).	Can	Tourism	‘Seal	the	Deal’	of	its	Mitigation	Commitments?:	The	Challenge	of	Achieving	
    ‘Aspirational’	Emission	Reduction	Targets.	Background	study	for	the	symposium	‘Tourism	&	Travel	in	the	Green	Economy’,	
    14th to 15th September, 2009, Gothenburg.
2 These figures include international and domestic tourism flows as well as one day trips. The gap is due to scientific uncertainties
    regarding the climate effect of aviation related cirrus clouds. The maximum figure is based on model calculations of 2007 (cf. 1),
    updated with new data from the year 2009 (cf. 6).
3 UNWTO-UNEP-WMO (2008). Climate Change and Tourism – Responding to Global Challenges.
    Available online at
4; A return flight from Frankfurt/Germany to Santo Domingo/Dominican Republic causes 5,7 tons CO2-equivalent
    per passenger. The climate compatible budget of one person in one year is estimated to be 3 tons CO2-equivalent.
5 UNWTO (2007). Davos Declaration on Climate Change and Tourism. Available online at
6 This statement needs to be seen with the limitation that only 10 % of the same respondents eventually consider information on
    product emissions important for their purchase decision.
7 European Commission (2009). Flash Eurobarometer 256: Analytical Report on Europeans’ Attitudes Towards the Issue of Sustain-
    able Consumption and Production. Available online at
8 ANEC-BEUC-ECOS-EEB (2009). Joint Position: Sizing up Product Carbon Footprinting.
    Online available at
9 Quack, D., Grießhammer, R., Teufel, J. (2010). Requirements on Consumer Information about Product Carbon Footprint.
    Background Study commissioned by ANEC. Freiburg: Öko-Institut e.V.
	   Online	available	at
10 European Commission (2008) Meeting Report: Commission coordination meeting on the carbon footprint measurement of prod-
    ucts. 4 March 2008, DG Environment.
    Online available at
11	Email	communication	with	Stefan	Gössling,	Researcher	on	Tourism	and	Climate	Change	Mitigation	at	Lund	University/Sweden,	
    on 23 April 2010
12	Email	communication	with	Paul	Peeters,	Associate	Professor	for	Sustainable	Transport	&	Tourism	of	CSTT,	NHTV	Breda	University	
    of Applied Sciences, on 31 July 2009
13 Email communication with Christian Baumgartner, Secretary-General of Naturefriends International and Member of the
    EU Tourism Sustainability Group, on 20 June 2010
14	Email	communication	with	Bill	Hemmings,	Policy	Officer	for	Aviation	and	Shipping	at	Transport	&	Environment,	on	17	June	2010
15 Email communication with Veronika Haunold, Head of Department, EU Environmental Bureau (EEB) in Vienna, on 16 May 2010
16	Email	communication	with	Stephan	Krug,	Project	Coordinator	at	Viabono,	on	5	May	2010
17 Product Carbon Footprint World Forum (2010). French Environmental Labelling Scheme: What to expect from Grenelle 2?
    Press release on 28 May 2010. Online available at
18	Gössling,	S.	(in	press).	Carbon	Management	in	Tourism:	Mitigating	the	Impacts	on	Climate	Change.	
19	WWF	(2009).	Der	touristische	Klima-Fußabdruck.	WWF-Bericht	über	die	Umweltauswirkungen	von	Urlaub	und	Reisen.	
	   Online	available	at


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