We consider that this PCR Draft is a really good document and it can play an important role in the communication activities between the companies in the lift sector. However, right now there are some companies in this sector working under the guidelines given under the ISO 14006 standard, so this standard should be part of international standards mentioned in the document (specially in General Introduction;
2.1 Voluntary information;
10.5 Additional environmental information
and 11.6 References). As it's not possible to add documents right now to the website, i send to the secretariat fo the EPD system my comments under the official template).

Here is the file for future reference.

/Kristian Jelse, Secretariat