1of15 Poste Italiane's comments to the PCR draft document

06 November 2013, 4:00:21 PM (GMT +1)

Para. 2.2, "Unaddressed mail": NB: the UPU regulation does not include the unaddressed mail product. We propose that this category be maintained, deleting the reference to UPU regulation.

by: Simona Condorelli

1of15 Poste Italiane's comments to the PCR draft document(2)

06 November 2013, 4:00:19 PM (GMT +1)

Para. 2.2, "Unaddressed mail": NB: the UPU regulation does not include the unaddressed mail product. We propose that this category be maintained, deleting the reference to UPU regulation.

by: Simona Condorelli

USE OF RESOURCES

26 September 2013, 4:57:27 PM (GMT +1)

Hi,
I have been analyzing some EDP and I’m wondering where does the data that is used to quantify - Non-renewable resources: (Material resources and energy resources) and Renewable resources (Material resources and energy resources) for the upstr...

by: Emanuel Lourenço

Attributional / book-keeping approach

23 September 2013, 9:02:11 AM (GMT +1)

In the 'Draft PCR for open consultation' there are references to "Book-keeping LCA approach (attributional LCA)" and that this is in accordance with principles set in ISO 14025.

Comment: It is problematic to referring to such principles since t...

by: Jannick Hoejrup Schmidt

Allocation

23 September 2013, 8:55:12 AM (GMT +1)

In the 'Draft PCR for open consultation' chapter 8 on page 18 it is written: "The method of avoiding allocation by expanding the system boundaries, as advocated in ISO 14044, is not applicable within the framework of the International EPD® System ...

by: Jannick Hoejrup Schmidt

DOWNSTREAM PROCESSES AND END OF LIFE

31 July 2013, 10:59:01 AM (GMT +1)

We think that END OF LIFE of  the product should be compulsory.
In our opinion, it is important to give an information about the end of life of the product in this PCR because it represents the “final link of the PCR chain  (see comment PCR and p...

by: Luca Sordi

DOWNSTREAM PROCESSES AND TRANSPORT

31 July 2013, 10:57:22 AM (GMT +1)

We think that delivery transport should be compulsory (according to specific company data) or using a pre-defined value in case of lack of information (e.g. 1.000 km by road)

by: Luca Sordi

Landfill in CORE

31 July 2013, 10:29:03 AM (GMT +1)

We note that you write in 7.1.1 “Waste that is sent to landfill shall not be included in the system boundaries”. We think that this is in contrast  with GPI 2.0 - A.6. ALLOCATION RULES .

by: Luca Sordi

Recycling in DOWNSTREAM

31 July 2013, 10:28:39 AM (GMT +1)

We note that you report in (DOWNSTREAM 6.3 – DOWNSTREAM PROCESSES) the recycling of packaging after use but this is in contrast  with GPI 2.0 - A.6. ALLOCATION RULES . 

by: Luca Sordi

Production of auxiliaries and CORE

31 July 2013, 10:22:57 AM (GMT +1)

As you have done for ADDITIVES PRODUCTION, we think that auxiliaries material production should be reported in UPSTREAM. What do you think about this? 

by: Luca Sordi