2516.01_Attachment 7-6

A_ TUVRheinland®
Precisely Right.

Mar. 23, 2015

Document Control Office (7407M}
Office of Pollution Prevention and Taxies (OPPT)
Environmental Protection Agency
1200 Pennsylvania Ave. NW.
Washington, DC 20460-0001

Re: Comments on the Criteria/Qualifications that will be Used for the Selection of the
Multi-stakeholder Panel Members and Expression of Interest as Ecolabel Programs to be
Assessed per the Draft Guidelines (Docket ID: EPA-HQ-OPPT-2014-0838)

To Whom It May Concern,
TOV Rheinland appreciates the opportunity provided by EPA to comment on the
criteria/qualifications that will be used for the selection of the multi-stakeholder panel members
and to express interest as ecolabel program to be assessed per the draft guidelines for product
environmental performance standards and ecolabels for voluntary use in Federal procurement.
TOV Rheinland, founded more than 140 years ago, is a global leader in independent testing,
inspection and certification services. The Group maintains a presence at around 500 locations
in 66 countries with 18,000 employees. The independent TOV Rheinland experts stand for
quality and safety for people, the environment, and technology in nearly all aspects of life. TOV
Rheinland evaluates technical equipment, products and services, oversees projects and helps
to shape processes for companies. Its experts train people in a wide range of careers and
industries. TOV Rheinland employs a global network of approved labs, testing and education
centers. Since 2006, TOV Rheinland has been a member of the United Nations Global Compact
to promote sustainability and combat corruption.
To help manufacturers promote their eco-friendly products with one mark in a faster, more direct
and efficient way, in January 2012, TOV Rheinland launched Green Product Mark scheme,
which is a voluntary environmental label for products that will give consumers and buyers
guidance in identifying green and sustainable products in the often crowded market place. The
Green Product Mark, along with the relevant regulatory requirements, aims to minimize the
impact of products on the environment.
TOV Rheinland is committed to helping institutional buyers to distinguish environmentally
preferable products from others through the good practice of environmental labelling scheme
operation. To test the effectiveness of the draft guidelines for product environmental
performance standards and ecolabels for voluntary use in Federal procurement, TUV
Rheinland volunteer to participate in the pilot project in 2015 to undergo the assessment
against the draft guidelines for three pilot product categories. TOV Rheinland would also
be committed to continuously contributing to the refinement of draft guidelines.

A. TUVRheinland®
Precisely Right.

TOV Rheinland's comment on criteria/qualifications for the selection of the multi-stakeholder
panel members is as below:
•

It would be suggested that "Knowledge of Green Building Certification/Rating Scheme
(e.g. LEED; Green Globes)" be added into multi-stakeholder panel member
criteria/qualifications. Eco-labels for those three pilot product categories (furniture,
building flooring, and building paints/coatings/removers) constitute significant credits
undei prevailing green building certification/rating schemes. Understanding the logic of
green building certification/rating system would in turn facilitate the interpretation of ecolabelling requirements.

We look forward to contributing to the future evaluation process of the draft guidelines as a
member of stakeholder panel and participating as an eco-label program owner in the pilot
assessment against the draft guidelines. Should you have any question regarding the comment
or Eol l provided, pis contact me via [email protected] .

Head of Green Solutions
TOV Rheinland