PCR Partnership Programme

Downloading a PCR is not different from downloading any other type of product via the web

Whenever you buy a product/service from a web-source you usually get a manual or source of information on how to make use of the product and under which circumstances. This is a necessity for you as a user to eventually refer to a guarantee in case of problems using the product. It is also a security for the product/service-provider to deny any claim of pay-back in case of misuse of the product.

What do relevant ISO standards say?

There are two ISO documents setting the rules and requirements for making use of existing PCR – ISO 14025 on Principles and Procedures for Type III environmental declarations (EPDs) and ISO/TS 14027 on Development of PCR. The most important parts are referred to below.

ISO 14025: 6.7.1 Developing the contents of a PCR document
Programme Operators (POs) should facilitate harmonization when developing PCR for a product category by considering the adoption of readily available PCR documents in the same product category and in the appropriate market area. However, there may be valid reasons for developing PCR documents that have different content from those that are already existing. The justification for differing from existing PCR shall be based on the content of existing PCR documents, and shall, not for example, be based on the origin of any particular PCR. The efforts undertaken to achieve harmonization, outcome and the explanations for not using readily available PCR shall be reported in the PCR document.

ISO/TS 14027: 6.4.3 Adaption of existing PCR
Existing PCR may be adapted. Any adaption of an existing PCR shall:

   a)   fulfil the requirements of applicable standards including this document and ISO 14025
   b)   fulfil the general programme instructions of the PO
   c)   integrate additional guidelines which increase the PCR relevance in order to improve representativeness

After a PO has identified an existing PCR in the same product category, it can either apply the PCR without further adaption or review or amend it integrating additional guidelines. In both cases, the PO shall assign a registration code to each PCR, which will serve as its unique identifier.

Some identified problems

The interest for EPDs is growing on a global scale in almost all sectors of society mainly because EPDs are the only internationally recognized tool intended to allow a purchaser or user to compare the environmental performance of products on a life cycle basis. From the current focus of making use of EPDs in the building and construction sector, other sectors are gradually paying more attention to develop EPDs in the future.

It is quite a resource-intensive undertaking to become a PO with all administrative duties that need to be carried out and maintained. All these tasks for a PO are described in Annex B in ISO/TS 14027 and ISO 14025. This is especially true for PCR development with all its activities from initiating the work to the final phase including the comprehensive information that should be publicly available in connection to the registration of the PCR on a website (ISO/TS 14027 8.1.1 Identification of the PCR document).  

The ISO documents state that the application and/or adaption of existing PCRs shall be the preferred option, which is clear advice to all POs to strictly follow given principals and procedures when downloading existing PCRs. However, this is not an easy task to do in practice and the experiences gained so far indicate a market failure in many respects. Consequently, there is a clear risk for proliferation of PCRs in the same product category followed by a mistrust amongst customers in the private and public domain to make use of EPDs in the future.

The main reason for this market failure is that the information needed for making proper use of EPDs is usually not available on POs’ websites. Although POs are obliged to maintain publicly available lists and records of PCR documents and registered EPDs in the programme, they do not have to keep their GPIs publicly available in the same way (but being obliged to communicate their GPIs upon request). All POs shall prepare General Programme Instructions (GPIs) describing the operation of the programme which should cover also the use of existing PCRs. Without knowing the GPI of the PO and the specific prerequisites of the existing PCR to be adapted, it is almost impossible for any PO to download existing PCRs and fulfil the obligations as described in the ISO documents. 

Another problem is that it seems to be a common understanding in the recommendation in ISO 14025 to make use of existing PCRs that it is free of charge to download them and make use of them for all kinds of purposes without any contact or compensation to the PO who is owner (intellectual property rights) of the original PCR. If so, this would considerably disturb and jeopardize fair competition among POs as it would be easy to download an existing PCR, offer low prices for registrations of EPDs in the same product category and market area and, by doing so, outcompete the PO developing the original PCR.

As ISO standards can not include any aspect related to commercial use of the standards there is no guide about this in the ISO 14025 or ISO/TS 14027. However, considering the quite substantial costs that POs have to bear to manage the original PCRs, any serious PO wanting to offer its services based on other POs’ PCR in a business-like manner, will most likely be willing to accept some level of permission or economic compensation. 

Making PCRs publicly available include a clear responsibility for all EPD POs

Making use of PCR and EPD referring to ISO 14025 and ISO/TS 14027 emphasize that a special responsibility rests with all POs when publishing PCR. In case any PO wants to apply existing PCRs developed originally by other POs or find motives for making adaptions to them, they also carry clear responsibilities. Any PO should regularly update the PCR to reflect the best available practice, data and methods. Such a responsibility regarding the updating, revising and expiring of a PCR are illustrated below as a list of aspects that continuously need to be monitored and considered in a POs operational work.

ISO/TS 14027 9: Updating, revision and expiration of PCR

 

a) changes to general programme instructions and supplementary materials referenced by the PCR
b) changes to overarching standards
c) Changes in secondary data sources or parameters that apply to the programme as a whole
d) Update to methods for additional environmental information that apply to the programme as a whole
e) expiration or obsolescence of the original PCR document
f) technology and material changes to products in the category
g) changes to technical and quality standards for products in the category
h) availability of new LCA-based information generated in the relevant public or industry sector
i) evidence that the original PCR are too restrictive
j) the existing PCR are no longer supported by the majority of interested parties
k) the need to resolve previously unresolved issues

The overall responsibility for a PO developing and publishing an original PCR result from the fact that the PCR is recommended to be used by other POs. If other POs use the PCR without necessary information on how the PCR was developed and meant to be used and where, there is a risk for misinterpretation and misuse of the resulting EPD claimed by other parties, where the PO publishing the PCR in the first place could be standing accountable.

The overall responsibility for a PO downloading and making commercial use of an existing PCR is due to the intrinsic understanding not to apply or adapt existing PCRs that does not comply with its own GPI, thereby conflicting consistency of its EPD programme.

It is of course inappropriate to make use of existing PCR just because they are in the same market area (i.e. found to cover a specific product category). It is also worth noting that even if the GPI of POs are available (through websites or by means of other types of communication) they do not usually describe all aspects in detail to fully cover all underlying technical LCA discussions taking place when initially developing a PCR. There is usually a lot of vital information in such discussions that only can be transferred through a close and personal contact between POs. 

These are all general observations indicating limitations regarding guidelines given in ISO 14025 and ISO/TS 14027 to secure their full implementation on the market without demur. The business sector will most likely expect that voluntary initiatives will be taken to safeguard the best and professional possible use of the ISO standards to meet market requests for science-based, reliable and comparable ways to provide information on the environmental performance of products on a life cycle basis.

ISO 14025 says in the introduction that harmonization of GPIs and particularly PCR should be encouraged between EPD programmes to meet the principle of comparability. This should include common rules with respect to PCR development, PCR review and verification procedures, administrative procedures and declaration format. However, nothing is said how to accomplish this ambition in the standard. The only indication on this issue is mentioned in ISO/TS 14027 saying that when the PCR are adapted, the PO of the adapted PCR should inform the PO who developed the original PCR about the changes, however this is not mandatory to do.

The PCR Partnership Programme (PPP) offered by the International EPD® system is an attempt to overcome most of the limitations identified when making use of existing PCR without further notification or consultation between POs.

Why does it seem necessary to partner about PCRs?

There are several advantages by starting close cooperation and partnership between POs – the ones developing original and existing PCRs and the ones wanting to apply or adapt them. These are shortly illustrated in the following way.

Advantages for each of the POs
PO 1 developing the original and existing PCR PO 2 wanting to apply or adapt the existing PCR

Establishing a record of which POs that are making use of its PCRs as a base for possibilities to establish a joint PCR Registry

 

 

Getting access to information necessary to be able to justify the use or non-use of an existing PCR

 

Getting information from PO 1 of necessary changes in the PCR during its validity period

Getting information from PO 2 about observations of value for the upcoming revision of the PCR

 

 

Getting access to information during the development of the PCR or during the open consultation if questions arise during verification of an applied or adapted EPD

Getting insight into reasons for eventual adaptions of a PCR identified by PO 2

 

 

Getting access to information during the development of the PCR or during the open consultation as an input to eventual adaptions of a PCR

Advantages for both POs

Joint work on defining a logical hierarchical position of an adapted PCR in the form of referring to the existing registration code of the original PCR amended with annexes to describe the adaptions made

Cooperation during recurring open consultations when updating the joint PCR

Aligning existing PCRs published by both POs in the same product category

Assistance from both POs in case new PCRs are about to be developed

Combined outreach activities and marketing of joint PCRs

Establishing a cooperative economic agreement leading to a win-win situation for both parties during the commercial use of the joint PCR

Contact

For more information about the PCR Partnership Programme, please contact Sven-Olof Ryding, sven-olof.ryding@ivl.se. Please click here to get more background information.

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