Product Category Rules
Your Market, Your Rules
Product Category Rules (PCRs) are governed by ISO 14025: 2006 Environmental labels and declarations —Type III environmental declarations —Principles and procedures. PCRs help to minimize market confusion by streamlining the procedures by which products are evaluated for their environmental impacts, ensuring globally consistent data collection and analysis and consistent reporting in EPDs.
Product Category Rule harmonization with global EPD programs
Under ISO 14025:2005 Section 6.7, Labeling Sustainability shall facilitate harmonization when developing PCR for a product category by adopting readily available PCRs in that same product category. Modifying such PCRs shall be only for valid reasons that the current PCR does not adequately reflect the product in the product category. This serves several purposes:
It allows for harmonization among other program operators, their PCRs, and trade organizations with Labeling Sustainability.
Harmonization saves Labeling Sustainability's clients time and resources by utilizing the existing documents.
Accessing available PCRs and registering EPDs with Labeling Sustainability using approved PCRs gives clients choices when registering their EPD. Combining these factors makes harmonization an intelligent choice for Labeling Sustainability clients.
Procedure for registering EPDs
not currently accepted by labeling sustainability
If a company or trade organization would like to verify or register their EPD conducted to a different PCR, they must first contact Labeling Sustainability for approval. Suppose an EPD has already been completed using a non-approved PCR. In that case, the company or trade organization must first declare their intent to validate or register their Type III environmental product declaration with Labeling Sustainability and must submit the documents used. To gain acceptance for an EPD to be either verified or registered with Labeling Sustainability, the organization preparing the documents must provide:
The PCR used to create the EPD
The product life cycle assessment
The final EPD document
If the EPD has already been third-party verified and the sole intent of the organizations or consultant is to register the EPD, they must also provide the credentials of the verifier if not already approved by Labeling Sustainability. Once Labeling Sustainability reviews the documents, a response will be issued within ten business days.
PCRs created by labeling sustainability
Sub Product Category Rule for Site Furnishings, CSI Master Format, Section 32 33 00
Geoff Guest, PhD.
Ecogamut Consulting Inc.
November 11, 2021
November 11, 2026
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PCR review panel composition and transparent review process procedures
Current PCRs are non-harmonized and vary from operator to operator. Although still conforming to ISO 14025:2006, this consistency creates a lack of comparability among products even in the same market segment. This is particularly problematic in the building materials and construction market, where EPDs and the sustainable information they convey can be used to award a project to manufacturers and suppliers based on their impacts.
Efforts to create a global PCR database have not been fully committed, and every program operator has guidelines about which PCRs they will accept. A panel of experts who have a vested interest in the PCRs and the subsequent EPDs they produce is the goal of Labeling Sustainability. Since the scope of Labeling Sustainability as a program operator is building materials and construction products, the PCR Review Panel shall be comprised of individuals interested in these product EPDs.
Updating and revising PCRs
Program operators shall update PCRs to reflect the most current practices, data, and methods as they become available. A PCR Committee is not required to update a PCR; the program operator may act alone in making changes for the following reasons: (Ingwersen, 2013)
Changes to program operator rules or any supplementary materials referenced by the PCR, including the guiding standard, ISO 14025:2006
Updates to existing LCIA methods used by the PCR
Updates to methods for additional information that apply to the program as a whole
Before the PCR is updated, Labeling Sustainability shall notify the public of the updates made and allow comments to be submitted in response to those updates. Once all comments are recorded and responded to, and the final update is available, Labeling Sustainability shall make the updated PCR available on their website. In addition, Labeling Sustainability shall declare the time limit in which the old PCR can be used to register validated EPDs. The period shall be no less than three months to allow any projects currently using that PCR to submit their verified EPD for registration.
Revising a PCR
A revision of the PCR is to be made by the original PCR developer/program operating under the direction of a PCR review panel. Some reasons for revising a PCR include (Ingwersen, 2013)
Expiration of the original PCR
Changes in the technology and/or materials used to manufacture products in the category
Updates to ASTMs or quality standards for products in the category
A standard PCR shall be valid for a period of 5 years from the final date of acceptance by the PCR review panel. PCRs shall be considered invalid after the expiration date. The PCR review panel shall anticipate such changes and begin the renewal process in enough time that the renewed PCR is ready and available for use before the old PCR becomes outdated.
Application for independent verifiers and PCR review panel specialists
Interested parties wishing to become an independent verifier in the EPD system by Labeling Sustainability must meet the following criteria to ensure the consistency of data verification in both the LCA process and the EPD procedures following ISO 14025. The EPD system by Labeling Sustainability is focused exclusively on building materials and construction products; therefore, the requirements may be more specialized than other EPD programs. This can be through education, research, work experience, or personal interest.
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Application for independent verifiers and PCR review panel specialists by labeling sustainability