Three Practical Forms of “Carbon Labels” in Packaging and Printing: CFP / EPD / China Environmental Label — Three Things to Confirm When a Printer Receives a Customer Request for a “Carbon Report”
💡 💡 At a Glance
Carbon labels are divided into 3 categories: CFP (carbon footprint, RMB 15,000–30,000, 7–15 days) / EPD (environmental product declaration, RMB 60,000–120,000, 8–12 weeks) / China Environmental Label Low-Carbon (RMB 20,000–40,000, 4–8 weeks). When a printing plant receives a customer request for a carbon report, the first step is to ask the customer which category they require, rather than directly contacting a certification body; at the same time, verify the PCR number, validity period, and logo display specifications.
In September 2024, a Shenzhen printing company that produces packaging for exported cosmetics received an order for 120,000 gift boxes. The brand requested a product carbon footprint report by email. The printing company’s owner sent procurement staff to contact a certification body, which quoted 48,000 yuan and 3 weeks to issue the report. Considering the high price, the owner found another certification body that quoted 25,000 yuan and promised delivery in 7 days. The owner chose the less expensive option, but after receiving the report, the brand replied: “This is not what we need. We need an EPD.” The printing company did not get the 25,000 yuan back, nor did it get the order.
This failure is not because the printing plant did not try hard, but because it never distinguished what kind of carbon label was required. The carbon reports commonly referred to in the market fall into at least 3 categories, each with entirely different regulatory bases, third-party verification requirements, and validity periods. The first thing a printing plant should do upon receiving a client request for a carbon report is not to approach an institution, but to ask the client which type is required.
I. The three types of carbon labels are not the same
First, let’s clearly define these 3 categories:
Category 1: CFP (Carbon Footprint of Product)
Based on ISO 14067:2018, calculate the greenhouse gas emissions of a product from cradle to gate or from cradle to grave, typically expressed in kg CO₂e/unit product. Features:
CFP is the cheapest and fastest of the three categories, with the printer calculating the cost in-house and a third party signing and stamping it. Market price: 1.5-3 ten-thousand yuan; turnaround time: 7-15 days.
Category 2: EPD (Environmental Product Declaration)
Under ISO 14025:2006, the core is cradle-to-gate life-cycle environmental impact disclosure, covering not only carbon but also 6–8 categories of indicators, including acidification, eutrophication, ozone layer depletion, and water footprint. Key features:
EPD is the most expensive and slowest of the three options. To join the certification system of the EPD program operator, a printing plant must budget RMB 60,000–120,000, with a cycle of 8–12 weeks.
Category 3: China Environmental Label Low-Carbon Certification
Complies with GB/T 24025-2009 and Announcement No. 15 of 2021 from the Ministry of Ecology and Environment, “Technical Requirements for Environmental Labeling Products — Printed Products”. Features:
The China Environmental Label is the most commonly used of the three categories in China, mainly for packaging orders involving government tenders and procurement by large hypermarkets and supermarkets. The market price is 2-4 ten-thousand yuan, with a lead time of 4-8 weeks.
2. Differences in the Accounting Boundaries of the Three Types of Reports
What printing factory owners care about most: For the same carbon report, how do the accounting boundaries of these 3 categories differ?
The root cause of the Shenzhen printing company’s failure was that the client required an EPD, but the company hired a CFP institution. EPD includes 5-7 more indicators than CFP and must be conducted under the EPD program operator’s PCR—the PCR number for cosmetics packaging is PCR-2024-001 for cosmetics outer packaging. Before accepting the order, the printing company must confirm that the PCR number matches the brand owner’s.
III. Responsibilities of Type 3 Printing Plants and Brand Owners
The printing factory owner’s main concern is that I subcontracted the printing of “low carbon”; I must also bear responsibility—yes. The basis for this determination is whether the printing factory verified the brand owner’s carbon label report number during the proofing stage and checked the validity periods of the China Environmental Labeling Certification or EPD logo. If it did not verify them, it is deemed to have had constructive knowledge.
IV. Three-Step Self-Check for Printers Upon Receiving a Customer Request for a Carbon Report
Three Takeaways for Print Shop Owners
Practical recommendation: When a printing plant receives a customer order requiring a carbon report, the first document is the target report type specified by the brand, together with the PCR number and validity period requirements; the second document is a carbon-label usage undertaking signed and stamped by the brand. If either document is missing, do not start printing the low-carbon wording.
Further Reading
FAQ
Can a print shop produce its own carbon footprint report?
Yes, for CFP (Carbon Footprint of Product) accounting, but export clients almost always require third-party verification. For domestic small-to-medium brands, self-declaration by the print shop + third-party sign-off (in consulting form) may be accepted, but the report's authority is weaker. EPD must be published by an EPD program operator (such as IBU, UL, EPD Norway) — print shops cannot self-issue. China Environmental Labelling must be issued by CEC or its contracted bodies — print shops cannot self-issue.
How much do the quotes for CFP, EPD, and the Ten-Ring mark differ?
Approximate market price ranges: CFP ¥15,000-30,000 (7-15 days) / EPD ¥60,000-120,000 (8-12 weeks) / China Environmental Labelling Low-Carbon ¥20,000-40,000 (4-8 weeks). However, specific pricing depends on: ① product complexity (single material vs composite material); ② Scope 3 boundary (only raw materials vs through to transport); ③ third-party verification body (international vs domestic). When negotiating, print shops should not focus solely on the total price but clarify the boundaries.
How do you look up the PCR number for cosmetics packaging?
EPD program operators publish PCR documents on their official websites: IBU (Europe) website has cosmetics packaging PCR / EPD Norway has food packaging PCR / UL (USA) has industrial packaging PCR. Within China, EPDs are managed by CEC or the China EPD platform, with PCR number formats typically being PCR-Year-Sequence Category Name. Print shops should request the brand provide the PCR number and report template as the first step after order confirmation.
Is a client requesting carbon-neutral packaging the same as requesting low-carbon packaging?
No, these are not the same. Carbon neutrality requires Scope 1+2+3 (full or partial) emissions to be offset to zero through carbon credits, requiring additional purchase of carbon credits or afforestation offsets, with certification under PAS 2060 or ISO 14068-1. Low-carbon only requires accounting and displaying the carbon emissions per unit product, with no offsetting needed. When print shops receive carbon-neutral orders, they must clarify: ① whether the Carbon Neutral logo needs to be printed; ② whether the logo carries a PAS 2060 certificate number. Missing either item will be deemed false advertising.
What is the minimum size for carbon label logos printed on packaging?
This depends on the specific certification body: ① EPD logo minimum height 7mm, clear-space ≥1/4 of logo width, available in monochrome black or color; ② China Environmental Labelling Ten-Ring logo minimum height 10mm, clear-space ≥1/2 of logo width, green only (Ten-Ring standard green); ③ Carbon Trust logo minimum height 8mm, must be printed in color. Print shops must verify against the logo usage specifications provided by the brand at the proofing stage — do not confirm using rough proofs.
If a print shop has no carbon report itself, can it have the brand produce one when accepting a low-carbon order?
Yes, but with two prerequisites: ① the report provided by the brand must cover the processing stage of the print shop (Scope 1+2), not only the raw material stage; ② the print shop must verify on the proof that the product name, batch number, and production date on the report match the actual printed product. If mismatched, the print shop, even without issuing the report, bears joint liability for false advertising.
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