Nothing wrong with a little help in everyday life. Below you will find answers to most common PCR questions received.

What is a PCR?

PCR documents are the basis for Environmental Product Declarations (EPD) – voluntary, quantified and verified environmental information for a product in accordance with ISO 14025. The PCR provides rules for how to develop an EPD for a specific product category, including instructions for the underlying life cycle assessment (LCA) and other content of the EPD.

PCRs are developed in the framework of a programme operating in accordance with ISO 14025, such as the International EPD® System.

How do I find and access existing PCRs?

All PCRs of the International EPD® System are listed in the PCR Library. For downloading a PCR, you must register and log in to the EPD Portal. The Secretariat may assist you in finding the correct PCR. If you are uncertain on the applicability of a specific PCR, you may also contact the PCR Moderator.

How is a PCR developed?

The PCR development process is briefly described here and in more detail in Section 5 of the General Programme Instructions. All templates needed for the development process are available here.

Existing PCRs available at www.environdec.com shall be considered before starting the development of a new PCR to avoid overlaps in scope. Existing PCRs that cover a part of the life cycle of the product in question, such as agricultural products for processed food items, should be referenced for harmonisation across product categories and in supply chains.

Existing PCRs available in other programmes shall also be considered before developing a new PCR. Our work on global PCR harmonization include mutual recognition agreements (MRA) with other program operators and the PCR Partnership Programme (PPP).

How do I leave feedback or comment on a PCR?

During the PCR development process, there is an open consultation during which any interested party is welcome to provide comments. The open consultation is further described in Section 5.3 of the General Programme Instructions.

Also otherwise during PCR development, or during the PCR validity period, any stakeholder is welcome to provide comments on the PCR by contacting the PCR Moderator or the Secretariat by e-mail.

Who develops a PCR?

The PCR development shall be done in an internationally accepted manner based on an open, transparent, and participatory process either by:

  • companies and organisations in co-operation with other parties, such as trade associations and interest organisations,

  • institutions involving LCA/EPD experts in close cooperation with companies or trade associations and interest organisations, or

  • single companies or organisations in the event they have the necessary in-house competence or choose to engage outside LCA/EPD experts.

PCR development is done by a PCR Committee, coordinated by a PCR Moderator. The PCR Moderator is appointed by the programme operator based on an application, which is submitted to the Secretariat as part of the PCR Development Checklist. The PCR Moderator should have good project management skills, familiarity with EPDs and the industry/product category, and at least basic understanding of LCA. The PCR Committee should be balanced and include as many interested parties as possible from the geographical scope of the PCR, for example representatives from different companies and trade associations, to ensure broad acceptance and high quality of the final PCR.

The programme operator shall maintain the copyright of the document to ensure that it is possible to publish, update when necessary, and make available to all organisations to develop and register EPDs. Stakeholders participating in PCR development, either as part of the PCR Committee or by commenting during the open consultation, should be acknowledged in the final document and in the PCR Library at www.environdec.com.

What is the procedure for approving a PCR?

The final draft PCR shall be reviewed by the Technical Committee functioning as the PCR review panel, supported by the Secretariat. The review shall address:

  • whether the choices regarding LCA-based content (system boundary, allocation rules, environmental performance indicators etc,) and other content of the EPD are made according to the General Programme Instructions,

  • whether the PCR development process has been done according to the General Programme Instructions, and

  • how the PCR Moderator and PCR Committee have handled feedback received during the open consultation.

The results of the review should be documented in a PCR review report and shall lead to:

  • approval of the draft PCR, without need for changes,

  • approval of the draft PCR, after comments and suggested changes have been satisfactorily addressed, or

  • further review, after comments and suggested changes have been addressed.

If further changes are requested, the PCR Moderator and PCR Committee shall ensure that the review comments and suggested changes are considered in updating the draft PCR. The PCR may need several rounds of review by the PCR review panel and revision by the PCR Moderator and PCR Committee before its final acceptance.

What is the validity of a PCR

A PCR is valid for a pre-determined period of time to ensure that it is updated at regular intervals. This period is normally four years.

An expired PCR shall not be used to develop and register new EPDs, and shall not be used to update a published EPD to give the EPD a prolonged period of validity. To be possible to use for these purposes, the expired PCR shall first be updated with a prolonged validity period.

Where can I find the latest UN CPC classification?

The online version of the United Nations Central Product Classification is unfortunately no longer available. It may be downloaded in PDF format on this page: https://unstats.un.org/unsd/classifications/unsdclassifications/.

What can I do if the PCR I want to use is not valid anymore?

We try to update our PCRs before they expire, to prolong their validity period. In case a PCR has expired, the updating process has begun, but the updated PCR has not yet been published, the validity of the expired PCR can be prolonged with at maximum 1 year. The extension of the validity period can only be done once. Contact the Secretariat if you are interested in this opportunity: pcr@environdec.com.

How long does it take to develop a new PCR?

The full process usually takes 8-10 months. Normally from initiation to start of open consultation (i.e. the preparation of the first draft): 1-3 months. Open consultation 2 months. Update of the PCR based on the Open consultation: 1-2 months. Review: 6 weeks. Final update and publication 1-2 months.

How much work is it do develop a PCR?

For PCR Moderators, the workload will depend on several factors: the experience of the moderator, how many committee members there are, how many comments are received in the open consultation and in the review, etc. In a normal process the PCR Moderator is estimated to need about two weeks of full time during the 8-10 months development period.

PCR Committee members usually spend less time than the moderator, depending for example on the level of engagement and the working procedure. The moderator and the committee may organize their work in any way they want.

What is the cost for developing a PCR?

The only costs for the development of a PCR are the costs of the time spent by the PCR Moderator, the PCR Committee members and other involved parties. The Secretariat does not pay compensation for any of these costs.

How do I submit complaints on a PCR?

For our quality management it is very important that the Secretariat gets information if there are any irregularities with EPDs, PCR or other published documents. To file a complaint, send an e-mail to the Secretariat: info@environdec.com.

To handle the complaint, we need information about name, registration number, etc. of the document complained of. The complaint also must be clear in what way the document does not meet the requirements in GPI, ISO 14025, EN 15804 or other steering documents.

Anonymous complaints are not considered.

What is a pre-certified EPD?

A pre-certified EPD allows you to publish environmental information for a product that is covered by a PCR under development, in case the PCR is for a new product category. Pre-certification is not applicable for a product category in the event of an existing PCR (valid or expired).

A pre-certified EPD shall be based on the current version of the General Programme Instructions and be valid for at maximum one year. After this, the pre-certified EPD shall be updated based on the published PCR.

Read more about pre-certified EPDs in Section 6.1.1 of the General Programme Instructions.

Can I include multiple similar products in the same EPD?

Rules for including multiple similar products in the same EPD can be found in Section 9.3 of the General Programme Instructions. These rules are also listed below, with some specifications and changes that will be implemented in the next update of the GPI, to be released towards the end of 2022.

Note that a specific PCR may include deviations or specifications to these rules. Further, some PCRs are based an old version of the General Programme Instructions (version 3.01 or older) in which the rules may be different from the current version - we still recommend following the current version, as all PCRs will be updated according to this.

Several sets of results, reflecting different products, are not allowed to be declared in the same EPD. However, similar products from a single or several manufacturing sites covered by the same PCR and manufactured by the same company with the same major steps in the core processes may be grouped and thereby included in the same EPD. For such an EPD, there are three options:

  • For each indicator, declare the average results of the included products. This average shall be weighted according to the production volumes of the included products, if relevant. In this option, the average content shall be declared in the content declaration.

  • Declare the results of one of the included products – a representative product. The choice of the representative product shall be justified in the EPD, using, where applicable, statistical parameters. For example, the choice may be based on production volumes. In this option, the content of the representative product shall be declared in the content declaration.

  • For each indicator, declare the highest result of the included products (i.e., the results of a “worst-case product”, which may be the results of one or several of the included products). In this option, the content declaration shall include the lowest amounts of recycled and biogenic content of the included products and their packaging, respectively, and the information on environmental and hazardous properties of substances shall reflect the highest share and most hazardous such substances contained in the any of the included products.

The first two options are only possible if none of the declared environmental impact indicator results differ by more than 10% between any of the included products. The third option is possible also if variations are larger than 10%.

The option chosen shall be clearly described in the EPD.

In addition to above options, sector EPDs are possible. See more in Chapter 9.3.2 of the GPI.

For EPDs following version 1.1 of PCR 2019:14 Construction products, the 10% difference only applies for the GWP-GHG indicator and for modules A1-A3, and larger variations may be accepted if justified and if the variation is declared.

If the PCR is based on an old version of the GPI (version 3.01 or older), the EPD may include several products/product groups even if above requirements are not fulfilled, but then the results of each product/product group shall be separately declared. If the PCR is based on the current version of the GPI (version 4.0 or later), the EPD shall include no more than one set of results. This change of rules was done to improve machine-readability of EPDs and thereby facilitate digitalisation of the EPD system. To enable this change, the cost per EPD registrations was reduced significantly as of 1st January 2021. Even if older versions of the GPI allow the declaration of results for several products/product groups, we recommend you to declare no more than one product or average/representative product per EPD – to be prepared for a more digital future.

Note that you are not allowed to include a conversion factor in the EPD for the purpose of converting the declared results into results for products not covered by the EPD. The EPD is for a specific product or product group, and only the EPD content of that product/product group has been verified and may be considered EPD information. You may, however, include a conversion factor for other purposes, see the answer to the question "May conversion factors be included in the EPD?".

May I register an EPD for a product without 1-year production data?

In general, LCI data shall be based on data from at least 1 year of production. If such data is not available because the product has not yet been produced for 1 year, the LCI data may be based on data from a shorter time period (e.g. 3 months) provided that the data can be proved to be conservative or representative for 1-year data. In such cases, the product description shall include a disclaimer saying "Product recently on the market – LCI data is not yet based on 1 year of production" and the EPD shall be updated and re-verified when data from 1 year of production is available.

May the declaration of biobased or recycled content be based on generic data?

No.

When a product is made in whole or in part with biobased or recycled materials, the provenience of these materials (pre-consumer or post-consumer, in case of recycled materials) shall be presented in the EPD as part of the content declaration.

To avoid any misunderstanding about which material that may be considered “recycled material”, the guidance given in ISO 14021 shall be taken into account. In brief, the standard states that:

  • only pre-consumer or post-consumer materials (scraps) shall be considered in the accounting of the recycled materials, and
  • materials coming from scrap reutilisation (such as rework, regrind, or scrap generated in a process and capable of being reclaimed within the same process that generated it) shall not be considered as recycled content.

The declared share of biobased/recycled materials shall be based on the actual share of biobased/recycled material in the product (in average over the studied time period, normally 1 year of production). In other words, the share of biobased/recycled materials of, for example, global average production of the constituent materials, for example as stated in generic LCI datasets, shall not be used as the basis for the declaration of recycled content.

If the share of biobased/recycled materials is unknown, this part of the content declaration can be left out (unless otherwise required by the PCR) or it can be stated to be 0% (a conservative estimate) or unknown.

May conversion factors be included in the EPD?

Yes, conversion factors may be included for the purposes of:

(i) converting the declared results of a product group to results for specific products within the group, or

(ii) converting the declared results to results for another declared/functional unit.

For conversion factors to be possible, the results of all declared life-cycle stages/modules must scale linearly with the conversion factor.

The conversion factors must be verifiable, i.e., the underlying data for the conversion factors must be provided in the LCA report.

The conversion factors shall be included in the section Additional environmental information, although they may be referred to in the Results section.

Conversion factors can, however, not be included for the purpose of converting the declared results into results for products not covered by the EPD. The EPD is for a specific product or product group, and only the EPD content of that product/product group has been verified and may be considered EPD information.