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CPC code: 2111 and 2113 Meat of mammals Fresh, chilled or frozen Approval date: 2013-10-30 / Registration number: S-P-00495 Valid three years / Revision: 1 Environmental Product Declaration of Coop Beef Meat

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CPC code: 2111 and 2113 Meat of mammals Fresh, chilled or frozen

Approval date: 2013-10-30 / Registration number: S-P-00495 Valid three years / Revision: 1

Environmental Product Declaration ofCoop Beef Meat

Page 2

Beef Meat EPD • 2013-10-30

Coop

Eurocoop

Coop is the largest retailer in Italy with a turnover of 12,724 billion Euros in 2013. The Coop system is based on 8.2 million consumer members and includes

1,199 retail units. Coop Italia is the Marketing and Buying central of the consumer cooperatives: it is responsible for negotiating with industries and producers,

“Coop brand“ products development, quality and safety policies and marketing strategy.

Eurocoop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer

cooperatives in 20 European countries. Euro Coop represents more than 4,500 local and regional cooperatives, whose members

count more than 30 million consumers all over Europe. Cooperatives are companies belonging to the Consumers , which mainly

operate in food distribution. The total turnover has amounted to more than 76 billion Euro, with 36,000 retail stores and 450,000

employees . His Secretariat is based in Brussels. Coop Italy participates in all of Euro Coop’s working groups, which address priorities like food and retail policy,

sustainability policy and cooperative identity.

Euro Coop member countries

Bulgaria / Cyprus / Czech Republic / Denmark / Estonia / Finland

Germany / Hungary / Iceland / Israel* /Italy / Netherlands / Norway / Portugal

Romania / Slovak Republic / Spain / Sweden / Ukraine / UK

More info on www.eurocoop.org

* Observer member

Page 3

Beef Meat EPD • 2013-10-30

Coop product’s values

Health: Coop believes people’s health is an essential right and considers the protection of its consumers fundamental. Coop brand products are the end results

of a commitment to achieve the highest level of well-being for its members and consumers.

Environment: Coop considers environmental protection to be a primary duty; for this reason, it undertakes the verification of its own activities and those

related to its suppliers. Coop makes sure of being in harmony with the environment through the use of best available technologies and takes into account the

economic sustainability of actions.

Ethics: Coop acknowledges the values of democracy, human rights, solidarity, citizens’ individual responsibility and equity, acting in compliance with the

commitments and corporate social responsibility. Coop brand products are designed to meet these commitments.

Page 4

Beef Meat EPD • 2013-10-30

Coop brand products

Coop brand products are produced by selected suppliers who must comply with specifications and project requirements that have been designed according

to ”Coop values”. The Coop brand product offers a complete range of products to satisfy the everyday needs of a family, including 7 different products’ lines

designed to meet the specific needs of consumers.

2,656 products designed for consumers daily needs.

80 fair trade products.

528 organic food products and environmentally sustainable non-food products.

374 high quality products, that represent Coop’s commitment to provide the best gastronomic specialties.

22 products, with low fat, sugar and salt content, designed to ensure a proper nutritional intake for children.

176 products dedicated to the world of childhood including nutritional, hygiene and textile products.

67 products with specific nutritional features that contribute to the body’s wellness including “free from” products, such as gluten-free products.

Page 5

Beef Meat EPD • 2013-10-30

Introduction to Coop beef production chain

The Coop Italian beef supply chain, founded in 1990, consists of more than 90% of meat from adult bovine (beef and heifer) produced using animals born in

France and raised in Italy. The production chain is based on the complete knowledge acquired during the production, from the animal’s birth in France to the

raising phase in Italy and continues with the slaughtering phase and any subsequent processing steps, until the retail phase.

In 2013 about 154.300 adult bovine were purchased by Coop.

In 2013 Coop beef production chain was based on:

11 32

218 168 FARMS 11 SLAUGHTERHOUSES 3 DISTRIBUTION CENTERS

2 TRANSIT POINT

Page 6

Beef Meat EPD • 2013-10-30

Beef meat

This document is referred to the beef meat from adult bovine (bull or heifer) grown in Italy and sold by

Coop at its stores. The environmental impacts were calculated taking into account the entire production

chain starting from the animal’s birth until meat consumption as specified on PCR “CPC code 2111 and

2113 - Meat of mammals”.

Time coverage

Data are related to beef meat purchased by Coop during 2013.

Declared unit

The information is related to 1 kg of fresh edible bone-free beef meat from adult bovine bred in Italy,

ready to be bought by the customer in polystyrene packs or served at the store butcher’s counter.

Energy value 547.5 kJ (131 kcal)

Proteins 21 g

Carbohydrates 0.0 g

Fats 5.2 g

Dietary fibres 0.0 g

Sodium 49 mg

Potassium 313 mg

Cholesterol 55.5 mg

Nutrition facts per 100 g of beef meat (edible portion).

Average data considering front and hind cuts – CRA NUT.

Iron 1.5 mg

Phosphorus 185 mg

Page 7

Beef Meat EPD • 2013-10-30

Almost all of the adult cattle belonging to Coop

supply chain come from France, where the calves are

weaned and usually spend the first 10-12 months of

their life.

The information needed for the assessment of

this phase was collected from 5 French farms of

different sizes: Sca de Baumont, Jardoux, Debizet,

Landrieve, Gaec Bonnefont Guillot.

After this period spent in France, the calves are moved to Italy and raised in

Coop supplier farms for about 7 months. Once the animals reach the weight

of 620 kg, they are slaughtered. In order to assess the environmental impacts

of this phase, data were collected from 4 slaughterhouse plants: Inalca in

Castelvetro di Modena, Unipeg in Reggio Emilia, Colomberotto in Moriago

della Battaglia (Treviso) and Clai in Faenza (Ravenna).

The carcasses are then sent to the processing

platforms where they are portioned, vacuum

packed in different sizes and sent to the stores,

where the meat is packaged in trays or sold at the

store butcher’s counter. In other cases the meat is

already tray-packaged at the platform and shipped

to the store ready to be sold.

For the purpose of assessing the environmental burden connected to the

meat processing phase, primary data were collected at the Unipeg-Coop

centrale adriatica processing platform in Reggio Emilia and at the IperCoop

Torino Dora store butcher’s section.

Detailed information about the animals’ origin, places in which they were

raised and slaughtered are also available, on packaging labels, for the benefit

of customers.

UPSTREAM CORE DOWNSTREAM

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

General System Boundaries

1.000 km 350 km 250 km 200 km

Page 8

Beef Meat EPD • 2013-10-30

Calves birth and weaning

Beef calves come mainly from France. They are

usually born in farms located in the central regions

of France where they stay about a year, reaching

the weight of approximately 350 kg. During this

phase, the calves stay grazing apart from a brief

period in which they stay inside the stable due to

winter temperatures.

As regards the calculation of impacts during this

phase, the main hypothesis are about the food

given to the animals and in particular: when the

animals are grazing they are fed exclusively grass

(10 kg/day for the calf and 20 kg/day for the

mother cow).

During the winter period, spent in the stable, the

feed given to the cow is mainly composed of hay

(80%), barley and soy bean while the calf is fed only

with cow’s milk.

Data collected from the involved farms, concern

stables’ energy and water consumption, waste

production, amount of feed given to the mother

cow and the quantity of manure produced (by both

the cow and the calf). At the end of the weaning

period, the calves are moved to Italy: the impacts

associated with transportation has been estimated

assuming a distance equal to 1,000 km.

UPSTREAM CORE DOWNSTREAM

1.000 km 350 km 250 km 200 km

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

Page 9

Beef Meat EPD • 2013-10-30

Cattle breeding

After weaning, cattle are raised according to

the contract agreement between Coop and the

farmers. Coop regularly checks its application with

strict verification procedures. In order to develop

the calculation model, 168 production units were

analysed.

The whole fattening period takes place inside the

stable and feed is made of different types of food

including corn in various forms, which is considered

to be the most important, along with various other

cereals. Farmers could independently manage

feed as long as they respected the specifications

laid down by Coop.

In order to evaluate the impacts of this phase, the

whole farm management process was considered,

including the cultivation of food, energy and water

consumption, manure management and enteric

fermentation produced by cattle.

The impact of bovine transportation to the

slaughterhouse plants was calculated on a 350

km-distance basis.

UPSTREAM CORE DOWNSTREAM

1.000 km 350 km 250 km 200 km

Breeding farms are located in red coloured regions

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

Page 10

Beef Meat EPD • 2013-10-30

Slaughterhouse

The impacts of this phase were calculated using information derived from

4 plants chosen between the main plants that slaughtered adult cattle for

Coop (these plants covered about 82% of beef meat sold in 2013). The main

environmental impacts are related to energy and water consumption, in addition

to the management of slaughtering residues.

An important hypothesis is the relative efficiency (yield) of meat production.

In particular, in 2013 the average slaughtering weight was updated and the

following data was considered:

– Adult bovine weight: 620 kg;

– Dressed yield: 59%;

– Boneless meat yield: 82%.

UPSTREAM CORE DOWNSTREAM

1.000 km 350 km 250 km 200 km

COLOMBEROTTOMoriago della Battaglia - TV

www.colomberottoqualitanellecarni.it

UNIPEGReggio Emilia - RE

www.unipeg.it

INALCACastelvetro di Modena – MO

www.inalca.it

CLAIFaenza – RA

www.clai.it

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

Page 11

Beef Meat EPD • 2013-10-30

Transformation and preparation

UPSTREAM CORE DOWNSTREAM

1.000 km 350 km 250 km 200 km

NOvACOOP TORINO DORARETAIL STORE

BUTCHER’S COUNTER

COOPLOGISTICAL PLATfORM

Reggio Emilia - RE

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

After the slaughtering phase, half-carcasses were moved to processing

platforms where the meat was packaged in two different ways:

– Vacuum packaged (in PE bags) and then dispatched to the retail stores

equipped with butcher’s counters, where the beef cuts are further portioned

and packaged in EPS trays or sold over the counter;

– In EPS trays: in this case the packaged product is distributed to retail stores

ready to be sold to the final customer.

For EPD purposes, Reggio Emilia’s logistical-processing platform was chosen

because it is one of the main platforms that works and sorts products for Coop.

Page 12

Beef Meat EPD • 2013-10-30

Retail store

After beef meat processing at platforms, the

product is sent to retail stores, ready for being sold

(packaged in EPS trays) or, if necessary,

subsequently processed.

In retail stores equipped with butcher’s counters,

as the one analysed for this EPD (NovaCoop Torino

Dora), the product comes almost all vacuum-

packaged from logistical platforms and then it is

further processed and portioned in trays or sold

over the counter, on customer requirements’ basis.

In order to assess the environmental aspects

related to this phase, energy, water and packaging

material consumption were collected. Cold chain

electricity consumption - i.e. for cold storage and

department’s temperature maintaining - were also

included.

Transports’ impacts have been calculated on 200

km distance basis that is an average value between

platforms and retail stores.

UPSTREAM CORE DOWNSTREAM

1.000 km 350 km 250 km 200 km

* Photo of Antonella Di Girolamo for Coop.

Mother cow management

Farm management Slaughterhouse Meat processing Retail store

Page 13

Beef Meat EPD • 2013-10-30

Results, part I

1 kg of adult bovine boneless meat:

NON-RENEWABLE RESOURCESDATA REFERRED TO 1 KG OF ADUlT BOVINE

BONElESS MEAT

UPSTREAM CORE DOWNSTREAM

TOTALMOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFE

Material ResourcesIN GRAMMES

Magnesium(& compounds)

< 0.01 99.5 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 99.5

Potassium chloride 25.5 53.6 < 0.01 1.6 < 0.01 0.6 0.1 < 0.01 81.3

Limestone (CaCO3) 8.0 59.7 < 0.01 0.8 0.4 2.4 2.0 0.1 73.4

Sodium Chloride 1.7 45.7 < 0.01 0.3 0.3 5.2 0.7 0.1 53.9

Phoshorous 7.2 35.8 < 0.01 0.5 < 0.01 < 0.03 < 0.01 < 0.01 43.6

Others 3.7 14.8 < 0.01 0.2 6.4 0.6 0.3 < 0.03 26.0

Energy ResourcesIN GRAMMES

Coal 33.3 81.7 < 0.01 6.5 14.6 89.0 78.1 < 0.04 303.4

Oil 301.2 312.5 < 0.02 61.1 43.0 46.9 41.4 < 0.03 806.2

Natural Gas 69.8 114.2 < 0.01 10.8 29.3 214.9 143.8 < 0.03 582.8

Others < 0.05 < 0.01 < 0.01 < 0.01 0.2 < 0.01 < 0.01 < 0.01 0.2

RENEWABLE RESOURCESDATA REFERRED TO 1 KG OF ADUlT BOVINE

BONElESS MEAT

UPSTREAM CORE DOWNSTREAM

TOTALMOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFE

Material ResourcesIN GRAMMES

Wood & Biomass 2.9 3.4 < 0.01 0.6 26.1 13.5 9.1 < 0.01 55.5

Energy ResourcesIN MEGAjOUlE

Hydroelectric 0.3 0.7 < 0.01 < 0.04 0.1 0.6 0.6 < 0.01 2.2

Wind < 0.01 < 0.02 < 0.01 < 0.01 < 0.01 0.2 0.2 < 0.01 0.4

Solar < 0.01 < 0.01 < 0.01 < 0.1 < 0.01 0.2 0.2 < 0.01 0.4

Page 14

Beef Meat EPD • 2013-10-30

Results, part II

1 kg of adult bovine boneless meat:

* Direct water consumption that is equivalent to the Blue component of the Virtual Water Content.

NOTE – The numbers reported in the tables above are the outcome of rounding. For this reason total results could slightly differ from the sum of contributions of the different phases.

WATER CONSUMPTIONDATA ExPRESSED IN lITERS *

UPSTREAM CORE DOWNSTREAM

TOTALMOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFE

153.5 1,107.4 < 0.01 22.0 0.6 29.4 41.4 < 0.02 1,354.2

IMPACT INDICATORSDATA REFERRED TO 1 KG OF ADUlT BOVINE

BONElESS MEAT

UPSTREAM CORE DOWNSTREAM

TOTALMOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFE

Global Warming Potential GWP – kg CO2 equivalent 11.6 3.9 5.1 0.3 0.2 1.6 0.7 < 0.03 23.4

Ozone Creating Potential POCP – g C2H4 equivalent 2.6 1.6 0.9 0.2 0.1 0.5 0.3 < 0.01 6.2

Acidification Potential AP – g SO2 equivalent 248.9 27.4 62.6 1.9 0.7 3.1 2.1 < 0.01 346.6

Eutrophication Potential EP – g PO4 equivalent 90.9 44.0 14.3 1.1 < 0.05 0.8 0.8 < 0.01 151.9

WASTEDATA REFERRED TO 1 KG OF ADUlT BOVINE

BONElESS MEAT

UPSTREAM CORE DOWNSTREAM

TOTALMOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFE

Hazardous waste – IN GRAMMES 0.4 < 0.01 < 0.01 0.2 14.4 303.3 < 0.05 < 0.01 318.4

NON-Hazardous waste – IN GRAMMES 4.2 < 0.01 < 0.01 5.6 69.4 2,123.7 256.1 < 0.01 2,458.9

Waste to recycling – IN GRAMMES 1.9 < 0.01 < 0.01 < 0.01 16.0 901.2 90.0 < 0.01 1,009.2

Page 15

Beef Meat EPD • 2013-10-30

Home cold storage and cooking

Phases subsequent to slaughter and meat processing require an increase

in the number of hypotheses to obtain precise results. This consideration is

even more important for phases such as home cold storage and cooking. The

environmental impacts estimation associated with these two phases follows

what is suggested in the PCR reference document.

Home cold storage

It was estimated that beef meat, after being purchased by the customer, may

be stored in the refrigerator for 3 days. The Carbon Footprint related to

home cold storage, based on these assumptions, is equal to 0.19 kg CO2 eq

per kilogram of meat.

Cooking

Data regarding this phase is approximate, because it entirely depends on

consumer tastes and habits. For hypothesis, raw consumption and two

different cooking types were taken into account: cooking a steak in a pan for

5 minutes (the Carbon Footprint is 0.49 kg CO2 eq per kilogram of beef) and a

roast in a pot, for two hours (whose Carbon Footprint is equal to 3.22 kg CO2

eq per kilogram of beef).

Page 16

Beef Meat EPD • 2013-10-30

Results interpretation

Carbon footprint of Coop labelled beef meat

Environmental impact data have been rigorously calculated up to the slaughterhouse phase included.

After this phase, many factors may affect the final result making non-unique impact attribution per kg of meat.

Carbon Footprint of meat at slaughterhouse gate (dressed yield 59%).

Carbon Footprint of meat at the retail store. In order to evaluate this impact, it is necessary to consider boneless meat yield, intended to be 82%. This yield is not a fixedvalue and it depends on the desired beef cuts.

Impact of ready-to-eat meat taking into account home cold storage and cooking. Sincecooking procedures and habits could be very different, data are presented as a rangewhose extremes are: raw consumption (24.1 kg CO

2 eq) and two hours cooking in the

pot (26.8 kg CO2 eq).

Per kG Of CarCaSS

Per kG Of Meat at tHe retaiL StOre

Per kG Of ready-tO-eat Meat

18.5

23.4

24.1 26.8

kg CO2 eq

considered

scenario

Page 17

Beef Meat EPD • 2013-10-30

Results interpretation

Energy mix used in the analysed Italian stables that raised cattle for Coop:

80%

20%

100%

40%

60%

0%

2012 2013

13%

24%

63%

23%

24%

53%

ENERGy FROM BIOGAS COGENERATION

ENERGy FROM PHOTOVOlTAIC SySTEM

ENERGy FROM NATIONAl GRID

23%

24%

53%

BiOGaS

PHOtOVOLtaiC

NatiONaL Grid

farM

2013

ENERGy

Renewable energy produced in Coop farm suppliers

Final total results reported in this product declaration do not reveal the environmental interventions carried out by farmers and focused to reduce the

environmental burden of animal raising, considering that the farm management has a limited weight on the total life cycle impact (about 1-2%). For this reason,

some consideration on environmental sustainability of farms were done. One important aspect related to many Coop farm suppliers is the production of energy

from renewable sources; 2012 and 2013 data is compared below.

Page 18

Beef Meat EPD • 2013-10-30

Additional indicators

ADDITIONAL INDICATORS MOTHER COwMANAGEMENT

FEEDMANURE

AND ENTERICFERMENTATION

FARM PHASEAND OTHER

PRIMARyPACKAGING

PRODUCTION

SlAUGHTERHOUSEAND MEAT

PROCESSINGACTIVITIES

FINAl PROCESSING

AND TRANSPORT

PRIMARyPACKAGING

END-OF-lIFETOTAL

Ecological Footprint – global m2 48.9 39.5 < 0.01 0.7 0.5 4.5 1.9 0.1 96.0

Green Water – iN LiterS 14,361 7,926 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 22,287

Blue Water – iN LiterS 153 1,107 < 0.01 22 1 29 41 < 0.02 1,354

Grey Water – iN LiterS 120 1,957 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01 2,076

Totale – iN LiterS 14,634 10,990 < 0.01 22 1 29 41 < 0.02 25,717

Vir

tual

Wat

er

Co

nte

nt

Page 19

Beef Meat EPD • 2013-10-30

Glossary

EUTROPHICATION POTENTIAl – EP

GlOBAl wARMING POTENTIAl – GWP

ACIDIFICATION POTENTIAl – aPIt is a form of precipitation that is unusually acidic, meaning that it possesses substandard levels of pH. It can have harmful effects on plants, aquatic animals and infrastructure. Acid rain is caused by emissions of SO2, NOx and NH3. The acidification potential is measured in grams of equivalent Sulfur Dioxide (SO2).

It is an extreme proliferation of vegetation in the aquatic ecosystem caused by the addition of nutrients into rivers, lakes or ocean, which determinates a lack of oxygen. Eutrophication potential is mainly caused by emission into water of phosphate and nitrates. It is expressed in equivalent grams of PO4

-.

PHOTOCHEMICAl OzONECREATION POTENTIAl – POCP

Chemical reactions brought about by the light energy of the sun. The reaction of nitrogen oxides with hydrocarbons in the presence of sunlight forms the ozone in the troposphere. The indicator mainly consists of VOCs (Volatile organic compounds) and is usually expressed in grams of equivalent ethylene oxide (g C2H4).

Also known as Carbon Footprint (CF), it represents the total amount of greenhouse gases produced along the entire Life Cycle. It is expressed in mass equivalent of carbon dioxide (CO2 eq).

MaLe CattLeMale cattle aged over 12 and under 24 months, raised for meat production.For Coop, the age range is between 16 and 22 months.

feMaLe CattLeFemale cattle aged over 12 and under 24 months, who has not given birth yet.For Coop, the age range is between 13 and 22 months.

aduLt BOViNe It generically means the beef cattle, both male and female, more than 12 months old.

Page 20

Beef Meat EPD • 2013-10-30

Additional information

This declaration and further regarding information are available at: www.environdec.com

References

– International EPD® Consortium;General Programme Instructions (EPD);ver. 2.01 of 2013/09/18

– PCR for Meat of mammals, fresh chilledor frozen; ver. 2.0 of 2013/07/22

– ISO 14040/14044:2006, ISO series onlife Cycle Assessment, www.iso.org

– IPCC Guidelines for National Greenhouse Gas Inven-tories Volume 4 Agriculture, Forestry and Other land Use chapter 10 emissions from livestock and manure management, www.ipcc-nggip.iges.or.jp

– Software SimaPro ver. 8 www.pre.nl

Technical report

Coop Italia life Cycle Assessment of Beefand Veal Meat, detailed hypothesis, rev.1.3.

PCR review

conducted by International EPD® SystemTechnical Committee

Indipendent verification

CCPB srlViale A. Masini, 36 – 40126 Bolognawww.ccpb.it

Accreditation approved by:Accredia

Independent verification of the declarationand data, according to ISO 14025:2006

EPD verification EPD Process verification

ContactsFor additional information relative to Coop activities or in regards to this environmental declaration, please contact:

Claudio Mazzini Coop Italia – Innovation, Sustainability and Values Manager

Francesca GuarnieriCoop Italia – Innovation, Sustainability and Values [email protected]

Nicola BrinaCoop Italia – Coop Meat and Fish Product Manager

Sara DagaCoop Italia – Meat and Fish Supervisor

Technical support and graphic design

life Cycle Engineering srl – Italywww.lcengineering.eu

Environmental declarations published within the same product category, though originating from different programs, may not be comparable.

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