C2. We think that the PCR should contain precise reference to the international standards. In particular, the technical specifications which has been required (e.g. Table 2.1) should contain the indication of clear test methods in order to allow a more contextualised evaluation of the environmental performances of the compared products.
C3. The note 5 of the paragraph 4 (page 8), “Any component present in % higher than 10% has to be specifically indicated (cannot be in other materials)” is not so clear and it could create some misunderstanding because it contrasts with the general rule: The gross weight of materials should be declared in the EPD at a minimum of 99% of one functional unit.
C4. In the general system boundaries scheme (page 9) and in the subsequent paragraphs it is not clear where are positioned the recycling processes (e.g. mechanical recycling, depolymerisation, etc.), polymerization operations and other typical man-made yarns and fibres processes.
These processes should be better defined in the scheme and in the subsequent descriptions.
C5. Concerning the data quality rules we suggest to insert the rule to use specific data for monomers/polymers production and recycling processes if they are carried out within the company who develops the EPD (see paragraph 8.2 of PCR “CPC 355, Man made fibres – synthetic”). In fact, these processes are decisive in the environmental impact assessment on man-made yarns category.
C6. Concerning to the rule at 7.1.1 “Waste from the process can be considered to be a by-product if constituting a substantial part of the overall company revenues…”, it is not clear and should refer to the products which effectively have an industrial application in other processes and are not intended for WtE (waste to energy) or other energy production processes.
We are looking forward to a prompt reply.