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Guidance on interpretation of programme instructions

Sometimes the programme instructions are difficult to interpret in terms of some of its requirements and recommendations. Guidance on the use is provided by the Technical Committee, and is incorporated into future versions of the document.

In the meantime, this guidance is available on this page.

Procedure for developing EPDs of products not yet on the market 

There is a potential demand for the development of EPDs for products that are designed and planned for future marketing, although they are not yet available on the market. This may occur, for example, in public procurement when companies are requested to provide customized versions of their standard range of products. The development of such EPDs poses the following compliance issues with the GPI:

  • Since these products are not yet manufactured, the declaration of the reference year of production (§9.5.3 Product Information) may not be available,
  • The lack of specific data related to manufacturing processes may make the system model not in line with the data quality requirements established for the application of the LCA methodology (A.5.2)

It was decided by the Technical Committee to adopt the following procedure to overcome these issues.

Procedure for developing EPDs of products not yet on the market
Products designed and planned but not yet launched on the market (forthcoming products) may be included in an EPD provided that the EPD owner has a validated LCA model for a similar product (as defined in §9.3.1) and the latter is compliant with the GPI and the applicable PCR (e.g. a registered EPD for a similar product is available).

Moreover, a similar product is defined as a sibling product when its LCA model is equal to the one of the forthcoming product in terms of data composition. The only differences regard the activity data (e.g. a different material or packaging composition share, a different energy consumption in the manufacturing process, a different distribution distance).

If the environmental profile of the forthcoming product is built based on a sibling product, the data quality requirements in A5.2 of the GPI are assumed to be fulfilled.

Table 1 provides a fictious example of sibling products association. The text in bold represents the sensitive data to be addressed in the application of the procedure.

When differences between products are not limited to activity data but involve changes in the LCA model, e.g. use of different materials in product assembly or the use of a different manufacturing technology, a similar product is defined a non-sibling product.

In this case, the LCA model of the forthcoming product may be equally built based on the similar product, but the EPD owner shall prove that data quality requirements in A5.2 are met. In such case, the EPD owner is allowed to use available inventory data for comparable technologies existing on the market (e.g. data from competitors or other manufacturers) and qualify them as specific data.

Forthcoming products may be then presented in an EPD using the impact of a similar product (either sibling or non-sibling) or through separate results depending on the provision in §9.3.1 of the GPI.

EPDs for forthcoming products shall contain in the product description section the following disclaimer:

  • Product not yet on the market

Verification of forthcoming products shall be carried out in accordance with the principles and procedures in Section 7.

The environmental profiles of forthcoming products shall be updated and re-verified after 1 year of actual production.

In both cases, regardless of the association to a sibling or non-sibling product, the presentation of the environmental profiles in EPD follows the provision in §9.3.1 of the GPI.


Clarification regarding indicators for use of resources and waste

As with the indicators for environmental impacts, these indicators account for resource use and waste generation data along the whole life cycle of the declared product (upstream, core processes and downstream processes). They are the result of the Life Cycle Inventory, and represent flows of resources and waste entering or leaving the system boundary after all processes are included. They are also known as “elementary flows”, as they represent the resource use and waste generation along the life cycle of each of the materials, processes, transports, etc. used in the studied system. See Figure below.

When declaring use of resources and waste production in an EPD, “elementary flows” data must be summed and declared (i.e. data along the entire life cycle of each of the materials, processes, transports, etc.) and not only flows related to the core processes (i.e. data directly taken from the Life Cycle Inventory of the EPD owner).

Please note that the amount of wastes and the destination shall be declared as outflows from the system only when it is not possible for some reason (such as the database framework or lack of information) to include their treatment processes (final disposal) in the LCA calculation as any other process

 Image explaining indicators for resource use and waste

Figure1  Illustration that indicators for use of resources, environmental impacts and wastes all concern the whole life cycle, and those flows that leave the system boundary.

As an example, a zero value for the indicator of radioactive waste would mean that nuclear power is never used during the life cycle of the product in neither of the processes consuming electricity, including the upstream processes. This is a rare situation as LCI datasets used for upstream processes usually include national electricity mixes, often having nuclear power in the generation mix. When using datasets of generic materials from LCI databases, this kind of radioactive waste flows are present as they represent generic manufacturing processes with generic electricity mixes and should thus result in a non-zero value in the EPD.