Analyzing the Institutional Attribute of Product Carbon Footprint Certification: A Name-Substance Mismatch Perspective Based on Conformity Assessment Theory
Product carbon footprint (CFP) certification has become a central instrument in global carbon governance, yet a systematic misunderstanding of its essential nature persists among industry practitioners. Drawing on the ISO/IEC 17000 conformity assessment framework, this paper proposes a conceptual distinction between "process-oriented requirements" and "threshold-oriented requirements," and systematically analyzes a three-dimensional mismatch between the name and substance of CFP certification at the linguistic, textual, and institutional levels. The findings are as follows: (1) At the cognitive-linguistic level, the term "certification" automatically activates the public's cognitive schema of threshold-based certification, which contradicts the process-oriented substance of ISO 14067/GB/T 24067. (2) At the textual level, ISO 14067:2018 does not use the term "certification" anywhere; all 12 core principles and the quantification methodology constitute process specifications. (3) At the institutional level, both the EU CBAM and the EU Battery Regulation are fundamentally process-verification mechanisms, using punitive default values to enforce data traceability. Using the compliance practices of Chinese battery enterprises exporting to the EU as a case study, this paper empirically validates the principle that "when process is absent, outcomes become invalid." The contribution of this paper lies in introducing conformity assessment theory to the analysis of CFP certification for the first time, constructing a three-dimensional analytical framework of the name-substance mismatch, thereby providing a new theoretical foundation for the improvement of CFP certification systems and the optimization of corporate compliance strategies.
关键词
产品碳足迹认证/合格评定/ISO 14067/过程认证/结果认证/认知错位
Key words
product carbon footprint certification/ conformity assessment/ ISO 14067/ process certification/ outcome certification/ cognitive mismatch
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