U.S. EPA Criteria for Product Category
Rules (PCRs) to Support the Label Program
for Low Embodied Carbon Construction Materials
(EPA's PCR Criteria) (Version 1—2024)
Office of Chemical Safety and Pollution Prevention
EPA-740-R-24-009
August 2024
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Table of Contents
Introduction 1
Challenges with Current PCRs and Standards 2
Development of EPA's PCR Criteria 3
Context and Related Efforts 3
National Efforts in Improving PCRs 3
International Efforts in Improving PCRs 4
EPA's EPD Assistance Grant Program 4
PCR Development Process Resources 5
Future Use and Efforts 5
LCA Context 6
Life Cycle Stages and Information Modules 6
LCA(s) Supporting PCRs 7
Comparability of Product LCAs 8
EPA's PCR Criteria 9
1. PCR Scope and Reference Disclosure 10
1.1. Scope of PCR 10
2. Criteria Addressing LCAs in PCRs 17
2.1. LCA Criteria (for Both Reference LCAs and LCAs Produced for the PCR) 18
2.2. Reference LCA Criteria (Only Applicable If an LCA Is Not Produced for the PCR) 22
3. Specification of Data 23
3.1 Data Collection Specification 23
3.2 Specification of Primary and Secondary Data 24
3.3 Facility Emission Data Specification 29
Appendix A: Overview of EPA's Efforts to Improve Free-to-Use and Publicly Accessible Secondary
Datasets within the United States 34
Appendix B: List of Criteria 35
Appendix C: Recommended Text Associated with ENERGY STAR 36
Recommended Text Associated with Criterion 1.1.1 36
Recommended Text Associated with Criterion 3.3.C 37
Appendix D: Additional Information on EACs and RECs 38
Technical Considerations 38
Criteria from Section 3.3.F 39
Recommended Questions for Verifying and Auditing EPDs with EACs and Improving Future Guideline
Development 44
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Appendix E: EPA's Recommended PCR Reviewer and EPD Verifier Qualifications 46
PCR Review Panel Qualifications 46
EPD Verifier Qualifications 47
Appendix F: Reasoning for Preference of Use of Free-to-Use and Publicly Accessible Datasets in LCAs49
Federal Government Use of Standards 49
Risks to Federal Agencies When Commercial Terms (Including Proprietary Datasets) Are Used in
PCRs 49
Appendix G: Recommended Charts to Include in PCRs 51
Appendix G.1: Recommended Data Disclosure Charts for PCRs 51
Appendix G.2: Recommended Data Disclosure Charts for EPDs 52
Appendix H: Additional Information and Recommended Text Associated with Recycled Content
Disclosure Requirements 53
References 54
Terminology 59
List of Abbreviations 62
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Introduction
The Inflation Reduction Act, passed by Congress and signed into law in August 2022, leverages federal
procurement and funding of buildings and infrastructure to catalyze markets for American-made
construction materials with lower embodied carbon (also known as lower embodied greenhouse gas
emissions). The following two sections of the Inflation Reduction Act provided the U.S. Environmental
Protection Agency with $350 million:
• Section 60112 of the Inflation Reduction Act of 2022 provided EPA $250 million to develop a
program to support the development of reporting criteria for environmental product declarations
and to enhance their standardization and transparency. These reporting criteria include
measurements of the embodied GHG emissions of the material or product associated with all
relevant stages of production, use and disposal. The reporting criteria also ensure the EPDs
conform with international standards for construction materials and products.
• Section 60116 of the Inflation Reduction Act of 2022 provided EPA $100 million to identify and
label construction materials and products with substantially lower levels of embodied GHG
emissions (associated with all relevant stages of the product's life cycle) than similar materials
and products.
EPA has developed an approach for EPA's Label Program for Low Embodied Carbon Construction
Materials ("Label Program Approach") per Section 60116 of the Inflation Reduction Act. The Label
Program Approach includes three phases, which are material agnostic, applicable to any material, and
allow materials to move through them at their own pace:
• Phase I: Data Quality Improvement. Standardizing and improving the quality of data used to
calculate the embodied carbon associated with construction materials and report this
information to the market via EPDs.
• Phase II: Threshold Setting. Determining thresholds that product types need to meet to be
labeled under this program, based on robust EPDs and other credible and representative industry
benchmarks and data.
• Phase III: Labeling Materials and Products. Labeling construction materials and products that
meet thresholds set by EPA.
The primary goal of EPA's label program is to create an easy and reliable way for purchasers to identify
and procure lower embodied carbon construction materials and products. During Phase I of the label
program, EPA will review the product category rules that govern EPD development under material
categories that are seeking to label their products to ensure they align with EPA's PCR Criteria. Also, as
part of Phase I efforts, EPA is investing in improving secondary LCA data in coordination with other
federal agencies.
The success and efficacy of the label program depends on EPA's ability to access and use
representative, accurate and verifiable data to set thresholds for specific product types. As such, EPA's
label program will build on the Agency's work under Inflation Reduction Act Section 60112 to support
the development of EPDs and EPD reporting criteria and enhance their standardization and
transparency. EPDs provide quantified environmental data related to the life cycle stages declared.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
They are developed using PCRs, which provide a set of specific rules, requirements and guidelines for
developing EPDs for one or more material categories or product types.1
This document outlines requirements and recommendations that PCRs must meet for applicable
materials and products to be eligible under EPA's label program.2 Program operators responsible for
developing and maintaining PCRs, PCR committees and PCR review panels can use this document to
ensure that their PCRs can be used to develop EPDs consistent with EPA's label program requirements.
As much of this document is based on existing International Organization for Standardization
standards, this document further clarifies and amplifies the existing standards and best practices in the
marketplace.
EPA's PCR Criteria are divided into three distinct sets of criteria: "baseline" criteria that PCRs are
required to meet now, baseline criteria that PCRs need to meet by 1/1/2026, and "leadership" criteria.
The baseline criteria are the requirements that PCRs must conform with for the material category
covered by the PCR to be eligible for EPA's label program. The baseline criteria are necessary to ensure
consistency within the material category and enable EPA to use the resulting EPDs to develop product
type thresholds for the label program. The leadership criteria are considered best practices and
strategies to further improve standardization, data transparency and quality. While PCRs do not need to
conform with leadership criteria at this time, EPA may consider requiring them as part of the baseline
criteria in the future. EPA's PCR Criteria as a whole highlight the larger need for increased rigor in the
field of PCRs and EPDs, while also recognizing the current state of the industry and relevant ISO
standards.
Program operators and/or PCR committee members who would like EPA to assess PCRs against EPA's
PCR Criteria should contact embodiedcarbon@epa.gov for more information on how to participate. EPA
is currently prioritizing PCRs covering concrete, asphalt, steel and glass. EPA expects to complete the
first round of assessments of PCRs covering key construction materials in fall 2024 and will continue to
perform assessments in additional material categories, depending on program priorities and resources.
Challenges with Current PCRs and Standards
There is a lack of consistency in the data quality requirements and process development approaches
program operators use to develop PCRs. Within the United States, PCRs are currently subject to ISO
standards and technical specifications—namely ISO 14025:2006, ISO 21930:2017 and ISO/Technical
Specification 14027:2017, as well as technical guidance documents. However, these standards,
specifications and guidance documents do not adequately support the following:
• Transparency and consistency with respect to the scope of EPDs developed under the PCR
• Rigor and consistency in PCR review processes
• Transparency and consistency with respect to life cycle assessment-based data inputs and
calculation methodologies
• Requirements for reference LCAs and LCAs that are developed for the PCR
• Procedural aspects of PCR development that are reconciled with voluntary consensus standard
processes and other ecolabel program management concerns
1 Note that PCRs are not "rules" in the EPA regulatory sense.
2 This document focuses exclusively on PCRs. Additional requirements related to EPA's label program will be established
separately; those requirements will include guidance relating to EPDs.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Development of EPA's PCR Criteria
As part of establishing the PCR Criteria, EPA received input from external stakeholders via EPA's
Request for Information process and a public comment period for the PCR Criteria. These criteria are
also a product of the Interagency Team on PCR Coordination, which includes representatives from
numerous federal agencies.3 While this document was authored by EPA's Office of Chemical Safety and
Pollution Prevention, it represents substantial input from the following federal partners and reflects
their expertise regarding EPDs and public procurement:
• The U.S. Department of Agriculture
• The U.S. Department of Defense
• The U.S. Department of Energy
• The U.S. Department of Transportation, Federal Highway Administration
• The Federal Emergency Management Agency
• The General Services Administration
• Numerous national laboratories (e.g., Pacific Northwest National Library, National Renewable
Energy Laboratory, Department of Commerce's National Institutes of Standards and Technology).
• Other key EPA offices, including the Office of Air and Radiation, Office of Research and
Development, and Office of Policy.
Context and Related Efforts
PCRs, as defined in the ISO 14025:2006 standard, are a requirement for the creation of Type III EPDs.
PCRs provide material- and/or product category-specific rules, requirements and guidelines for
calculating and reporting environmental data across a product's life cycle. Rules analogous to PCRs
exist for other types of LCA-based product claims, such as product carbon footprints and product
environmental footprints, and other forms of quantitative product environmental footprints. PCRs can
support both business-to-business and business-to-consumer communication.4
National Efforts in Improving PCRs
Over the past decade, there have been several additional efforts to improve and standardize PCRs. In
2013, the Product Category Rule Development Initiative published "Guidance for PCR Development." in
which Ingwersen et al. noted the need for standard PCR templates and to directly connect LCAs to the
development of PCRs to ensure consistent environmental impact reportingwithin categories. In 2019,
the American Center for Life Cycle Assessment released an ISO 21930 guidance document that was
developed to address a need within the LCA community for clear, consistent guidance for interpreting
non-life cycle impact assessment metrics during PCR and EPD development and application.
In 2022, ACLCA released an update to the "Guidance for PCR Development" titled "2022 ACLCA PCR
Guidance—Process and Methods Toolkit." This ACLCA PCR Guidance consists of three checklists: one
for the program operator, one for the PCR committee, and one for the PCR review panel. The checklists
3 For information on where EPA and other federal agencies are participating in PCR committees, please visit our website:
Product Category Rule Standards and Related Initiatives.
4 Per the 2013 Guidance for PCR Development (Inewersen etal., 2013).
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
outline specific criteria to follow when developing or updating PCRs, as well as how to determine
conformance with each criterion. EPA is grateful for the efforts ACLCA and multiple other stakeholders
have undertaken to develop the ACLCA PCR Guidance. Many of EPA's PCR criteria outlined here are
based on and build upon the ACLCA PCR Guidance.
However, the 2022 ACLCA PCR Guidance was published prior to EPA's directive under the Inflation
Reduction Act to develop a label program for low embodied carbon construction materials. While the
2022 ACLCA PCR Guidance suggests helpful improvements to standardize PCR content, format and
development, it does not address certain aspects related to data quality and transparency. Therefore,
EPA has developed these PCR Criteria to provide more prescriptive guidance to further enable the use
of EPDs in public procurement and EPA's label program.
Concurrent with efforts in the United States to improve PCRs, trade associations, state and local
governments, academic institutions, and architecture and engineering firms have invested significantly
in developing PCRs. Over the past few years, private industry leaders have established PCRs for their
respective product categories for North America. In some sectors, this has resulted in wide-scale
adoption of EPDs for the disclosure of environmental impacts. This disclosure has enabled both public
and private purchasers to estimate their impacts, conduct more thorough whole-project LCAs, and
contribute to the development of various state and local government Buy Clean and sustainable
procurement initiatives. Without this early private sector investment, efforts to standardize PCRs and
EPDs would not be possible, and EPA appreciates efforts taken by these stakeholders and looks
forward to continued collaboration via EPA's current Low Embodied Carbon Construction Materials
Program efforts.
International Efforts in Improving PCRs
Some institutions outside the United States are undertaking efforts to globally standardize PCR
practices and approaches, as well, including the Secretariat of the Clean Energy Ministerial's Industrial
Deep Decarbonization Initiative, hosted by the United Nations Industrial Development Organization.5 In
April 2024, these efforts resulted in the release of the Secretariat's Guidance for PCR Harmonization, on
which EPA provided input based on its stakeholder engagements relating to the PCR Criteria. This
release illustrates how governments across the world are seeking to collaboratively standardize PCRs
to consistently convey information about the embodied carbon associated with materials and products
across geographic regions. While national governments may have different perspectives on certain
items as they pertain to LCAs, PCRs and EPDs, EPA acknowledges that a key first step is to be involved
in international standards development to learn from and improve upon domestic efforts. As such, EPA
is also committed to engaging with relevant ISO Technical Advisory Groups to update foundational
standards, such as ISO 21930:2017, to improve PCRs and EPDs as a whole.
EPA's EPD Assistance Grant Program
As part of Section 60112 of the Inflation Reduction Act of 2022, EPA's Grant Program: Reducing
Embodied Greenhouse Gas Emissions for Construction Materials and Products has selected 38
businesses, universities and nonprofit organizations serving all 50 states to receive funding in fiscal year
2024. Selected projects fall under five broad categories:
5 While the U.S. government participates in this effort, the outputs of this group, such as documents or other guidance,
are not to be construed as endorsements or reflective of the official position of the U.S. government or the U.S.
Environmental Protection Agency.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
• Robust Data for EPDs: Projects that contribute new and/or improve critical data, analysis or
feedback for producing robust EPDs
• Robust Product Category Rule (PCR) Standard Development, PCRs, and Associated
Conformity Assessment Systems: Projects that encourage the development of robust,
standardized PCRs, including identifying what data needs to be collected for EPDs, how that data
should be collected, how it should be reported in EPDs, and what transparency and verification
needs to be in place to ensure credible EPDs
• Robust Tools & Resources to Support & Incentivize Development and Verification of EPDs:
Projects that contribute to the development of tools and resources to make it easier, faster and
more cost effective to produce and disclose robust EPDs
• EPD Development and Verification: Projects that offer construction material and product
manufacturers assistance in producing robust EPDs, or in which a construction material or
product manufacturer is producing robust EPDs
• Robust EPD Data Platforms and Integration: Projects that support EPD reporting, availability
and verification; support the standardization of disparate EPD systems; and support future EPD
integration into construction design and procurement systems
These efforts will support an increase in the development of EPDs in line with EPA's PCR Criteria to
meet the goals of the Inflation Reduction Act.
PCR Development Process Resources
EPA's Framework for the Assessment of Environmental Performance Standards and Ecolabels for
Federal Purchasing (2024) may be used as a resource to further align PCR development processes with
voluntary consensus standards processes and other ecolabel program management best practices.
EPA uses this framework to assess product and service environmental performance standards. The
framework includes criteria to verify if a standard's development process ensures openness,
transparency, stakeholder balance and due process—all important to the federal government.
Specifically, the Framework includes internationally accepted protocols for standards development
organizations (e.g., ANSI Essential Requirements) and U.S. government laws and policies relevant to
standardization, including Section 12(d) of the National Technology Transfer and Advancement Act, the
Office of Management and Budget's Circular A-119, and the U.S. Government National Standards
Strategy for Critical and Emerging Technology. Section I of EPA's Framework for the Assessment of
Environmental Performance Standards and Ecolabels is a resource for aligning standards development
procedures with U.S. government standards policy. Most PCR program operators have not yet fully
adopted these approaches, even though they are voluntary consensus standards developers
accredited by the American National Standards Institute. PCR program operators interested in
technical assistance in better aligning with voluntary consensus standards approaches may contact
EPA.
Future Use and Efforts
While EPA is primarily pulling from existing practices used in the global LCA community and ISO
standards, the Agency acknowledges that there are numerous cross-sector harmonization challenges
that this version of EPA's PCR Criteria does not currently address (e.g., consistency in allocation
methods across product categories). It is EPA's position that true cross-sector harmonization cannot
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
occur without a voluntary consensus standard that incorporates stakeholders from various
construction material sectors, governments, LCA practitioners and other relevant parties. EPA's PCR
Criteria are intended to fill this gap until such a voluntary consensus standard and associated
conformity assessment program is developed. EPA would welcome the use of the PCR Criteria as a
starting point for such an effort.
As these and other efforts evolve due to the rapidly growing use of PCRs and EPDs, EPA will consider
updating or sunsetting the PCR Criteria as needed to reflect changes in the market.
LCA Context
To help readers of this document identify connections within EPA's PCR Criteria to key existing
standards, here is an overview of LCA and PCR elements specified in existing standards and where
these elements are covered in this document.
Life Cycle Stages and Information Modules
The impacts associated with a product depend on the scope of the LCA that calculated them. Scopes
vary across LCAs but can often encompass life cycle stages such as production, use and end-of-life
treatment. Each of these major stages can comprise multiple processes. ISO 21930:2017 delineates
and defines broad and universal life cycle stages for construction EPDs (see Figure 1).
Construction works assessment information
a Replacement information module (B4) not applicable at the product level.
Figure 1: Life Cycle Stages and Modules for Construction Works Assessment Information from ISO
21930:2017, Section 5.2.1 (see Figure 2 of ISO 21930:2017).®
In ISO 21930:2017, module A1-A3 encompass the mandatory production stage: A1, extraction and
upstream production; A2, transport to factory; and A3, manufacturing. The other stages are A4-A5
6 ISO 21930:2017 Section 3.1.8 defines "scenario" as a "collection of assumptions and information relevant to possible
future events.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
(construction stage), B1-B7 (use stage), C1-C4 (end-of-life stage), and D (potential net benefits from
reuse, recycling or energy recovery). PCR committees can use these ISO stages—as well as industry-
specific process-level knowledge—to establish standard scopes for the PCRs and the LCAs developed
under them. LCA scopes can also include other specified characteristics, such as the defined
functional or reference units, type of LCA (e.g., product-specific, industry average), and reported
environmental indicator categories. For EPDs to be comparable, the LCAs underpinning them must
align in their scopes. When LCA scopes differ, certain products' EPDs may inadvertently appear to
perform better or worse than alternatives, potentially leading to issues when using these data for public
procurement. As such, Section 1 of EPA's PCR Criteria focuses on ensuring that PCRs used to develop
EPDs for the label program have a clearly established scope.
LCA(s) Supporting PCRs
It is important to differentiate LCA(s) supporting PCRs from underlying LCAs that individual EPDs are
based on. PCRs represent the rules for how to calculate the LCA-based data reported in an EPD within a
given product category. To ensure comparability among EPDs within a given product category, PCRs
must effectively anticipate product category-specific strategies that practitioners follow when
developing EPDs. Thus, one or more LCA(s) must be used to inform the PCR development process. As
outlined in Section 6.7.1 of ISO 14025:2006, program operators and other interested parties should
collect and/or produce appropriate LCA(s) that inform development of the PCR (see Figure 2 and Figure
3). This LCA supporting the PCR should communicate the datasets it relied upon, evaluate and provide
reasoning for industry-specific modeling decisions, and detail how it handled routine LCA activities
(e.g., allocation, limitations, managing assumptions). LCA(s) that support the PCR thus play an
important role in PCR development as outlined by ISO 14025:2006. Section 2 of EPA's PCR Criteria
therefore seeks to evaluate the relationship between the PCR and its supporting LCA(s).
Figure 2: Steps in Preparation of a PCR Document from ISO 14025:2006, Section 6.7.1
(See Figure 1 Within ISO 14025:2006).
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Body
Organizations
Organizations
Organizations
Organizations
Organizations
Organizations
Organizations
Organizations
Organizations
Programme
operator
Programme
operator [e g
company(ies).
industry
sector, trade
association or
independent
body]
Programme
operator
Programme
operator
Programme
operator
Programme
operator
Programme
operator
Programme
operator
Interested parties
Interested parties
interested parties
interested parties
interested parties
PCR review
panel
independent
competent panel
members
Independent
verifier
Independent
verifier
Independent
verifier
Third party
Addressed
audience
independent
venfier
Flow
(steps and results)
Programme
development
General
programme
instructions
Product category
rules (PCR)
development
Draft Type III
environmental
declaration
Independent
venftcalion
Type III
environmental
declaration
Activities/procedure
Programme
establishment
Development of the
programme
(including open
consultation) Not
necessary if
programme already
exists
Development of the
PCR document
(including open
consultation) Not
necessary if PCR
already exist
Drafting of
declaration
Independent
verification
Recording and
publication of the
declaration
Communication
and use of the
declaration
Updating of the
declaration
Definition of product
category
Collection or
creation of product
category LCA-based
information
Development of the
PCR document
venftcation of lca
data
Independent
vesication of the
declaration
Third-party
verification
Not mandatory.,
except for B to C
(see Clause 9)
6 2, 6 3, 6 4.
6 5. 8 3
6.5. 6 7.03
6.7.t, 6 7 2,
6.7 1.6 72
, 72 1.
2.72 3
8 1 1.8.2,
8 I 3.8 3
8 1 4, 8 3
Communica-
tion is not
covered by
the scope of
this
International
Standard
7.3
Figure 3: Type III Environmental Declaration Program
ISO 14025:2006, Annex
Development and Operation Scheme from
A, Table A.1.
Comparability of Product LCAs
Impact assessment results can vary between life cycle datasets representing the same activities and
scopes due to several factors, such as data source, comprehensiveness of inventory data, inventory
collection methods, geographic or temporal discrepancies, allocation methods, or even the impact
assessment method used. Beyond guidance on use of life cycle inventory datasets, PCRs can affect the
comparability of LCAs in how they instruct practitioners to develop foreground data. ISO 14025:2006
Section 6.7.2 outlines key requirements for the comparability of product LCAs developed from PCRs.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
For example, each LCA must contain a functional unit, system boundary and data description, among
other items. To ensure that LCA practitioners produce comparable LCAs and corresponding EPDs with
ease, Section 3 of EPA's PCR Criteria focuses on ensuring comparability and consistency of EPDs and
their LCAs by evaluating how PCRs manage data prescription, quality and collection.
EPA's PCR Criteria
The tables that follow in Sections 1.1 through 3.3 provide each PCR criterion—stating the criterion
number, the criterion text (i.e., how to fulfill that criterion), the related ACLCA PCR criterion and ISO
reference(s), and/or other notes as applicable. EPA is not mandating that PCRs meet these criteria in a
regulatory sense. Rather, material categories seeking to participate in EPA's labeling program will be
required to have PCRs that conform with the baseline set of criteria outlined within this document. This
is to ensure a transparent, fair, technically sound, level playing field for all construction materials and
products seeking to participate in EPA's label program.
Criteria #
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
Criterion ID
Baseline or
leadership
criterion
designation
Description and specification of the criterion text
Any standards,
guidance or other
references used to
construct the
criterion text
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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1. PCR Scope and Reference Disclosure
When creating a new PCR or updating an existing PCR, it is critical to ensure that the scope indicates the product types covered by the PCR, as
well as the reporting requirements for EPDs based on the PCR. This section outlines specific requirements for PCR scopes.
1.1. Scope of PCR
Criteria
#
B/L
Criterion
AC LCA PCR
Guidance/ISO/
References
1.1.A
B
The product category scope of the LCA(s) used for the PCR shall be within the scope of
the PCR. The scope of the LCA(s) used for the PCR shall serve as the justification of the
PCR and its functional (or declared) unit (see Section 2.1 .A for PCR reference to the
supporting LCA).
AC LCA 2-9;
ISO 14025:2006 Clause
3.14,6.6,6.7.2;
ISO/TS 14027:2017 Clause
6.5.2,6.5.3
1.1.B
B
The PCR shall include a clearly defined and measurable functional or declared unit.
ACLCA 2-11;
ISO 21930:2017 Clause
7.1.2,7.1.3
1.1.C
B
The PCR shall indicate the types of EPDs that are allowed with respect to life cycle
stages covered, with potential options including cradle-to-gate (A1-A3), cradle-to-gate
with options (A1-A3, plus other identified information modules), or cradle-to-grave (A1-
C4). The PCR should indicate which life cycle information modules are included for a
given EPD type. See ISO 21930:2017 Clause 5.2.2 for more information.
ACLCA 2-10;
ISO 21930:2017 Clause
5.2.1,5.2.2
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
1.1.D
B
PCRs that allow EPDs to report information modules beyond cradle-to-gate (either
cradle-to-gate with options or cradle-to-grave) shall include scenarios for each life cycle
stage beyond the gate that is allowed. When appropriate, the PCR should prescribe a
different set of assumptions, parameters and technical information for different product
types covered in the PCR. The scenarios should clearly indicate which product type the
scenario is connected to, its expected service life, and all other relevant assumptions for
each product type.
Note: If the scope of the PCR remains as only capturing information modules A1 to A3,
then this item is satisfied provided that the PCR clearly identifies that additional modules
and stages are excluded from being reported on EPDs that are developed under the PCR.
ACLCA 2-16
1.1.E
B
The PCR shall outline which EPD types may be developed with respect to data specificity
and state the specific data requirements for each type. Any other terminology describing
types of EPDs should be discouraged if it is not included within the PCR. At a minimum,
the PCRs must enable the creation of Type III, product-specific EPDs from a singular
production or manufacturing facility that are third-party verified against the PCR it was
made under (also known as product- and facility-specific EPDs).
Note: EPA understands that there is variation in the nomenclature associated with EPD
types and that this is impeding cross PCR alignment and compliance with local, state
and federal procurement language. EPA is also aware of efforts to establish a consistent
typology for EPDs and will continue to evaluate these efforts for potential future
incorporation into this criterion.
ACLCA 2-12;
ISO 21930:2017 Annex B
1.1.F
B
The PCR shall require that an EPD disclose its EPD type with respect to data specificity.
For average EPDs, refer to ISO 21930:2017 Annex B for terminology related to types of
average EPDs.
ACLCA 2-12;
ISO 21930:2017 Annex B
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
1.1.G
B
The PCR shall require that at a minimum, a cradle-to-gate (A1-A3) system boundary (and
any deviation) is explicitly specified and justified.
ACLCA 2-14;
ISO 14044:2006 Clause
4.2.3.3.1;
ISO 14025:2006 6.7.2b,
6.7.2c, 6.7.2j, 7.2.5;
ISO/TS 14027:2017 6.5.3b,
6.5.6
1.1.H
B
The PCR shall include criteria for deviation from the prescribed scenarios and require
that any such deviation be disclosed in the EPD.
ACLCA 2-16
Section 1.1—Leadership Criteria
1.1.1
L
The PCR should communicate requirements listing additional environmental
information including, but not limited to:
• Impacts on GHGs from biogenic carbon
• Impacts on GHGs without energy attribute certificates7
• Impacts on GHGs from Module D
• Additional ENERGY STAR information (see Appendix C for more information)
ACLCA 2-29, 2-39;
ISO 21930:2017 Clause 8.4;
ISO 14025:2006 Clause
7.2.3,7.2.4; ISO/TS
14027:2017 Clause 6.6
7 For example, assume the embodied GHGs for a product with location-based electricity accounting is 100 kg CC>2e/unit, and electricity accounts for 20% of that. The
manufacturing plant purchases EACs for half of its electricity purchases resulting in the product's embodied GHGs being 90 C02e/unit. The lifecycle impact results in
the main part of the EPD would disclose a GWP (see footnote 16) of 100 with a note explaining that it was calculated using market-based electricity accounting. The
Additional Environmental Information section of the EPD would additionally report that 90 C02e/unit is the GWP when location-based electricity accounting is used.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
These data will be communicated in a separate additional environmental information
section (either qualitative or quantitative information) and reference the methods and
format used to report additional environmental information.8
1.1.J
L
The PCR should require market-based accounting of impact indicators in the
quantification of impacts section of an EPD when EACs have been procured. In such
cases, location-based accounting of impact indicators shall be reported in the
"Additional Environmental Information" section of the EPD.
See Appendix D for more
information on EACs and
renewable energy
certificates.
8 EPA is aware that there may be emerging methodologies that may seek to be added to PCRs, such as alternative chain of custody methodologies. While EPA is not
endorsing the use of emerging methods, the inclusion of this text is intended to drive consistent and reliable reporting. As such, if the PCR committee outlines the use of
emerging methodologies which may result in shifts in the environmental impacts of a product, the PCR should disclose the use of such mechanism and include a
detailed description of the alternative chain of custody approach including the specific methodology used to attribute GHG emissions and any impact to the product
GHG emissions reported in the EPD. Such emerging methodologies must not conflict with the existing requirements of ISO 14025:2006, and ISO 21930:2017.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
1.1.K
L
The PCR should require the inclusion of a unique identifier on all EPDs that are made
under it. This should contain the following information:
• Entity producing the EPD (not the EPD owner)
• EPD Owner
• PCR Name and version number
• Year of EPD publishing
• EPD numeric count
• EPD version number
PCRs are encouraged (but are not required) to use the following Unique Identifier naming
convention:
• [Name of Entity Producing EPD]_[EPD Owner]_[PCR Name and Version
number]_[Year of EPD publishing]_[EPD numeric count]_[EPD version number]
For Example:
• ABC Tool Developer_ABC Producer_PCR-for-widgets_1,0_2024_00001_v001
This criterion will help with
provide transparency into
the EPDs version which will
aid implementors for
conformity assessment
efforts.
1.2. PCR Reference and Review Disclosure
1.2.A
B
The PCR shall thoroughly document the use of an existing PCR as an informative
document in any adaptation of an existing PCR. The creation of a new PCR that is part of
the supply chain or is affected by an existing PCR shall also comply with this criterion.
Include the program operator name, existing PCR name and product category
classification; link to the existing PCR; and provide justification for adapting the existing
PCR.
ACLCA 2-2;
ISO/TS 14027:2017 Clause
6.4.3;
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
1.2.B
B
The PCR shall list the referenced standards the PCR is in conformance with and link to
relevant program instructions. This should include year of publication of the referenced
standards.
Specifically, the PCR shall be in conformance with the following standards:
• ISO 21930:2017
• ISO 14025:2006
Note: Effective January 1, 2026, the PCR shall also be in conformance with ISO/TS
14027:2017.
ACLCA 2-6
1.2.C
B
The PCR shall list the specific standards it conforms to.
Note: Effective January 1, 2026, the PCR shall list any upstream and downstream PCRs it
aligns with.9 In cases where the PCR does not align with upstream and downstream
PCRs in areas of allocation (including recycling/recycled content allocation), cut-off
criteria, required secondary datasets, carbon capture utilization and storage, biogenic
carbon accounting, and any other aspect as determined by the PCR committee, the PCR
shall identify and explain such deviations.
Note: See Criterion 2. I.J for more information on allocation and harmonization with
upstream and downstream PCRs.
ACLCA 2-8;
ISO/TS 14027:2017 Clause
6.5.5
1.2.D
B
For PCRs that go out to review after the publishing of this document, a review panel shall
conduct a PCR review in accordance with ISO 14025:2006 and ISO/TS 14027:2017.
Note: Effective January 1, 2026, a PCR review panel shall use ISO/TS 14071:2014 to
organize and conduct the PCR review. The signed PCR review statement from the PCR
review panel shall indicate whether the review was done in accordance with ISO/TS
14071:2014.
ISO 14025:2006, Clause 5.7,
6.3.H,6.3.I,6.4.J, 8.1.2, 8.2;
ISO/TS 14027:2017, Clause
7;
ISO/TS 14071:2014
9 Upstream and downstream PCRs are not required to conform with EPA's PCR Criteria for products for the PCR under considerations to be eligible for the label
program.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria
#
B/L
Criterion
ACLCA PCR
Guidance/ISO/
References
Section 1.2—Leadership Criteria
1.2. E
L
Program operators should adopt requirements for PCR review panel members and EPD
verifiers within its General Program Instructions that are consistent with EPA's
Recommended PCR reviewer and EPD verifier qualifications as shown in Appendix E.
ISO 14025:2006, Clause
6.4.J, 8.1.2,8.1.4, 8.2;
ISO/TS 14071:2014 Annex B
1.2.F
L
The PCR should include a link to the program operator's website for the PCR committee's
documented public response to each comment received.
ACLCA 2-3
1.2.G
L
The PCR should include a permanent link to each of the previous editions of the PCR.
The PCR may also include a summary of changes made from the previous version.
This criterion will connect
the resulting PCR to prior
versions for transparency
into edits made between
versions.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
2. Criteria Addressing LCAs in PCRs
To ensure consistent environmental impact reporting in EPDs, it is necessary to build a PCR using either an LCA produced for that PCR10 or a
reference LCA. These differ based on when they were conducted. An LCA produced for a PCR is generated in conjunction with the PCR
development, while a reference LCA precedes the development of a PCR.11 Having LCAs produced for PCRs is in accordance with ISO
14025:2006,12 Section 6.7.1, in which a PCR committee determines the PCR scope, conducts an LCA(s), and outlines rules for consistent
modeling within the product category. Given this, LCAs produced for PCRs are preferable due to their synergies with the PCR; these LCAs lead
to mutually beneficial outcomes in both efforts and are consistent with ISO 14025:2006. When fully implemented, the criteria below will lead to
LCAs that algin in scope regarding covered products, impact assessments, system boundaries, allocation rules, prescribed flows and other
items covered within this section. However, due to time constraints with implementing EPA's label program and industry investments to date,
EPA is not favoring a PCR that has LCAs produced for it over a PCR that uses a reference LCA. Section 2.1 applies to both types of LCAs
(collectively referred to as "LCAs used for PCRs"), while Section 2.2 details additional requirements for "reference LCAs" only.
10 "An LCA produced for a PCR" constitutes the underlying LCA as defined in the "Terminology" section of this document under "LCA produced for the PCR (underlying
LCA)."
11 This section only addresses LCAs used in support of the PCR process and is not applicable to LCAs completed for each individual manufacturer EPD.
12 See ISO 14025:2006, Section 6.7.1, Figure 1, and Annex A-1.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
2.1. LCA Criteria (for Both Reference LCAs and LCAs Produced for the PCR)
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
2.1.A
B
The PCR shall be linked to an ISO 14040:2006/ISO 14044:2006 conformant
attributional LCA(s) and other relevant studies that inform the modeling of all product
types within the scope of the PCR. The LCA(s) shall meet the requirements of ISO
14044:2006, alongside other pertinent standards and will have been either critically
reviewed by a third party or undergone an internal verification, either by the PCR
committee or appointed independent LCA expert.13
AC LCA 2-5;
ISO 14040:2006;
ISO 14044:2006;
ISO 14025:2006 Clause 6.7.1,
6.7.2,8.1.3,8.2.1,8.2.2;
ISO/TS 14027:2017 Clause 5.1,
6.1,6.5.3,7.1d
ISO/TS 14071:2014
2.1 .B
B
The LCA report must be publicly posted and accessible via a web link included in the
PCR. The publicly posted LCA(s) shall include the required minimum nonconfidential
information outlined in Clause 5 of ISO 14040:2006. Additionally, the LCI data within
the LCA(s) used for the PCR may be aggregated to protect the confidentiality of
manufacturer-specific details.
This criterion will ensure the
LCA is disclosed.
2.1 .C
B
Both the LCA(s) used for the PCR and the PCR shall specify appropriate functional (or
declared) unit(s), scope of the study, inventory collection methods, impact
assessment, any allocation assumptions/rules, and additional information/rules. The
functional (or declared) unit can include at least two parameters to further define the
product such as area, mass and volume.
AC LCA 2-8;
ISO 14044:2006;
ISO/TS 14027:2017 Clause 6.5
13 ISO 14025:2006 requires PCRs to be based on one or more LCAs (in accordance with the ISO 14040 series of standards) and other relevant studies. These documents
are collectively referred to as the LCA(s) used for the PCR throughout this PCR Criteria document.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
2.1 .D
B
The PCR shall specify all core LCIA indicators for ISO-compliant LCAs and EPDs;
specifically listing the indicator with the LCIA characterization methodology and
provide a reference to the LCIA characterization methodology. At a minimum, this
should include LCIA indicators outlined in Table 5 of ISO 21930:2017. Alternatively, the
PCR shall specify additional information requirements for which relevant inventory
information shall be collected.
Note: The PCR is encouraged, but not required, to specify at least one LCIA method
that includes characterization factors for calculating results for each impact category
and each geographical region covered by the PCR.
ACLCA2-19; 2-37
ISO 14025:2006 Clause 7.2.2,
7.2.3;
ISO/TS 14027:2017 Clause
6.5.4,6.5.5,6.6;
ISO 21930:2017 Table 5,
Clause 7, Clause 9.5
2.1 .E
B
The PCR shall specify, based on the LCA(s) used for the PCR, all the inventory data, by
process, to be collected. Inclusion and cut-off criteria to inform these lists shall be
determined based on results of the LCA. The PCR committee shall communicate their
methods for performing cut-off analyses in the PCR. In cases where the LCA(s) used
for the PCR is not aligned with the PCR in terms of allocation or required secondary
datasets, decisions such as excluded parameters that fall below the cut-off criteria
shall be evaluated to ensure consistency with the allocation approach and required
secondary datasets in the PCR.
ACLCA 2-8, 2-20;
ISO 14025:2006 Clause 6.7.1;
ISO/TS 14027:2017 Clause 6.5,
6.6
2.1 .F
B
The PCR shall specify all parameters of assumed scenarios for major (as determined
by the LCA(s) in support of the PCR) use (B1-B5) and end-of-life (C1-C4) stages to
ensure comparability and consistency of results. PCRs may allow for deviations from
the default parameters and in such cases must specify the evidence that is required to
justify a deviation.
ACLCA 2-27
2.1 .G
B
The PCR shall specify which processes for relevant manufacturing steps are to be
subdivided. The PCR shall also provide guidelines on how the subdivision should be
performed, including the necessary primary data requirements, as informed by the
LCA(s) used for the PCR.
ACLCA 2-32;
ISO 14025:2006 Clause 6.7.1 c,
6.7.2c;
ISO/TS 14027:2017 Clause
6.5.3;
ISO 21930:2017 Clause 7.2.5.5
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
2.1 .H
B
The PCR shall prescribe ISO 21930:2017-compliant rules for allocation between
product systems (across the system boundary) and designate whether Module D may
be optionally reported in the EPD. If Module D is prescribed for inclusion by the PCR
committee, the PCR shall prescribe detailed calculation rules for any quantitative
metrics reported therein and require that results of Module D are reported separately.
ACLCA 2-36;
ISO 21930:2017 Clause 5.2.1,
7.2.6,9.4.7
2.1.1
B
The PCR shall specify where allocation by physical relationship is applied, specify the
relevant underlying physical relationships to be considered, and establish or refer to
the relevant allocation rules.
ACLCA 2-33;
ISO 14025:2006 Clause 6.7.1 c,
6.7.2c;
ISO/TS 14027:2017 Clause
6.5.3;
ISO 21930:2017 Clause
7.2.5.2, 7.2.5.5
2.1.J
B
The PCR shall define allocation procedures for reuse, recycling, and waste handling,
and for scenarios for treating waste generation during the product life cycle based on
the requirements in ISO 14044:2006 Clause 4.3.4 and ISO 21930:2017 Clause
7.1.7.2.7. If the PCR committee determines that a coproduct or byproduct exists, the
PCR shall demonstrate steps taken to reach harmonization across PCR boundaries,
such as reaching out to the impacted PCR committees to work toward cross-PCR
harmonization. If the PCR committee is unable to reach harmonization with related
PCRs but is aware of other PCRs' differing approaches, it shall report the alternative
allocation procedures used by upstream and downstream PCRs.
ACLCA 2-34;
ISO 14044:2006 Clause 4.3.4;
ISO 21930:2017 Clause
7.1.7.2.7
2.1 .K
B
The PCR shall not use system expansion as a method for avoiding allocation for
construction products that may involve the production of coproducts. Rather, the PCR
shall prescribe an ISO 21930:2017-compliant method of allocation based on the LCA
used for the PCR.
ACLCA 2-35;
ISO 14044:2006 Clause
4.3.4.2; ISO 21930:2017
Clause 7.2.5.4
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
2.1 .L
B
If an LCA report is produced for the PCR as part of the PCR development process, the
LCA produced for the PCR shall outline any gaps or data variations within its report and
the PCR shall outline these within the PCR itself.
Note: EPA acknowledges that there maybe emission data variability in the associated
primary and/or secondary data that can impede cross PCR alignment and the effective
use of EPDs as a procurement tool. EPA is aware of efforts to identify or define data
variability in EPDs, and currently is not in a position to endorse analysis or calculation
methodologies for data disclosure for LCAs, PCRs or EPDs.
ACLCA 2-41;
ISO 14044:2006 Clause
4.4.4.2; ISO 14025:2006 6.7.1 b
2.1 .M
B
The PCR shall include a system diagram(s) that represents all unit processes in scope
for the LCA used for the PCR. In cases where a product is typically manufactured
across several facilities, the system diagram(s) shall clearly visualize the separate
facilities and identify the various LCA modules for which impacts will be reported.
This criterion ensures that
PCRs clearly outline which unit
processes are being modeled
based on the LCA used for the
PCR. This enables a clear
disclosure of modeling scope
to end users.
2.1 .N
B
The PCR shall require EPDs to clearly disclose limitations to comparability as informed
by the LCA(s) used for the PCR.
ISO 14044:2006 Clause 4.5;
ISO 21930:2017 Clause 5.5
Section 2.1—Leadership Criteria
2.1.0
L
The PCR should use the LCIA indicator list outlined by EPA (please visit EPA's website
for the most recent file) until an update to the Tool for Reduction and Assessment of
Chemicals and Other Environmental Impacts (TRACI 3.0) is released. Once TRACI 3.0
is published, EPA encourages all PCRs to switch to TRACI 3.0 for LCIA indicators
outlined in Table 5 of ISO 21930:2017, in lieu of TRACI 2.1.
This criterion will help reach
consistency in IPCC global
warming potential factors used
throughout PCRs.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
2.1 .P
L
The PCR should list assumptions and limitations associated with findings from the LCA
used for the PCR. At minimum these should include assumptions outlined in ISO
14044:2006 Clause 4.5.2.1 and LCIA limitations outlined in ISO 14040:2006 Clause
5.4.3.
ACLCA 2-40;
ISO 14044:2006 Clause
4.5.2.3;
ISO 14040:2006 Clause 5.4.3
2.2. Reference LCA Criteria (Only Applicable If an LCA Is Not Produced for the PCR)
Criteria
#
B/L
Criterion
ISO References
2.2
B
If a PCR uses a reference LCA in lieu of an LCA produced for the PCR, the reference
LCA shall meet the following criteria, in addition to the relevant baseline criteria
identified in 2.1:
a. Is publicly accessible.
b. Was published within five years prior to the open call for participants of the
PCR.
c. Meets all relevant ISO standards that are outlined in this document (ISO
14040:2006, ISO 14044:2006, ISO 21930:2017, ISO/TS 14027:2017, ISO
14025:2006).
d. Has a scope aligned with that of the PCR.
e. Conforms to ISO 14044:2006 regarding LCAs.
f. Is attributional.
g. Conforms to the allocation rules of ISO 21930:2017.
ISO 14044:2006;
ISO 14040:2006;
ISO/TS 14027:2017;
ISO 14025:2006;
ISO 21930:2017 Clause 7
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
3. Specification of Data
To ensure the standardization and transparency of data reporting for EPDs, it is necessary to establish a standard of practice for the
specification of data within a PCR.
3.1 Data Collection Specification
Criteria #
B/L
Criterion
ACLCA PCR Guidance/ISO/
References
3.1.A
B
The PCR shall prescribe minimum required primary data collection practices and
data quality, as determined by the PCR committee and informed by the LCA(s) used
for the PCR. Primary data requirements shall be mapped to the appropriate unit
processes within the product system. All data shall be provided in standard SI units
in addition to any other unit(s) of measure specified by the PCR.
ACLCA 2-13, 2-18;
ISO 14044:2006 4.2.3.3;
ISO/TS 14027:2017 Clause 6.5.3;
ISO 21930:2017 Clause 7.1.9
3.1 .B
B
The PCR shall clearly specify the scope and data quality for secondary data and
include recommendations for free-to-use and publicly accessible datasets or
databases facilitating this process.
ACLCA 2-18;
ISO 21930:2017 Clause 7.1.9
3.1 .C
B
The PCR shall specify mandatory primary data that are to be collected for every
foreground process in the product system under the control of the organization
making the product claim. The PCR shall also specify that data specific to the
investigated product scope and supply chain shall be used over generic data unless
such specific data are not available. The PCR's specifications of the type of data to
be used shall be supported by LCAthat supports and aligns with the scope of the
PCR.
ACLCA 2-24
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
Section 3.1—Leadership Criteria
3.1 .D
L
The PCR should specify the type of data to be collected and appropriate methods for
primary data collection (e.g., metered utilities, standard formulas, direct
measurements). The PCR may provide templates to facilitate harmonized data
collection, metadata recording and results reporting (e.g., measured, calculated,
estimated). If the specified data collection means are unachievable for a specific
EPD developer, the PCR should designate that the developer records the data
collection method(s) utilized in the data description.
ACLCA 2-26;
ISO 14025:2006 Clause 6.7.2
3.2 Specification of Primary and Secondary Data
Criteria #
B/L
Criterion
ACLCA PCR Guidance/ISO/
References
3.2.A
B
Effective January 1, 2026, the LCA(s) used for the PCR shall include a complete data
quality assessment for both primary and secondary data, including the specification
of which DQA method was used.
Note: EPA understands that completing a DQA may be an intensive task for the LCA
practitioner tasked with conducting an LCA produced for the PCR. Further, if an
existing reference LCA is being used instead of producing an LCA for the PCR, it may
not be clear if a sufficient DQA is included. Additionally, given that there is no
consensus on which DQA methodology should be used, it can be challenging to
determine if a DQA that was previously conducted is sufficient, resulting in potential
confusion and ambiguity in terms of data quality. To address this, and to help program
operators. PCR committees and the LCA communitv. EPA has established a DOA
Methodologv.14 EPA's DOA Methodology is not required for compliance with Criterion
ACLCA 2-22;
ISO 21930:2017 Clause 7.1.9;
ISO 14044:2006 Clause 4.2.3.6;
ISO 14025:2006 Clause 6.7.2;
ISO/TS 14027:2017 Clause 6.2
14 EPA's DOA Methodology is available for use by other dataset providers and users. More information on the DOA Methodology, and how the federal government is
investing in improvements to free-to-use and publicly accessible datasets, can be found within Appendix A and on EPA's website.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
ACLCA PCR Guidance/ISO/
References
3.2.A. but it mav be used to achieve compliance. The use of EPA's DOA Methodologv
will ensure compliance with Criterion 3.2. H (leadership).
To aid stakeholders, EPA can conduct a DQA upon request for any PCR that covers the
United States and uses ISO 21930:2017 as its core PCR document, subject to
available resources. Please reach out to embodiedcarbon&epa.gov with anv
questions.
3.2.B
B
Specific data (i.e., from upstream EPDs) that are representative of the raw material
supply chain shall be used where possible. Where using specific data is not possible,
PCRs shall prescribe free-to-use and publicly accessible secondary datasets. PCRs
shall prescribe a unique free-to-use and publicly available secondary dataset for
each of the following flows:
• Electricity
• Fuels
• Transportation
• Other unit processes in which secondary data are required by the PCR
Note: Effective January 1,2026, PCRs shall prescribe the use of EPA-designated free-
to-use and publicly available datasets for the flows identified within this criterion.15
Prior to this date, PCRs that are being updated shall provide a commitment to use
public datasets in the future if they are not already using public data. If a PCR uses
private datasets, the PCR shall outline why public datasets are not adequate for the
flows the PCR is seeking to model.
This criterion addresses the
considerations outlined in
Appendix F on commercial terms
in standards.
15 EPA is actively working to improve free-to-use and publicly accessible datasets. At a minimum, this will include efforts relating to electricity, fuels and transportation
flows. More information on how the federal government is investing in improvements to free-to-use and publicly accessible datasets can be found in Appendix A and on
EPA's website.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
3.2.C
B
For PCRs that cover geographic areas outside the United States or model processes
that occur outside the geographic boundaries of the United States, the PCR
committee shall propose appropriate secondary datasets for each specific
geographic area or for technologies beyond the scope of the specified datasets for
relevant supply chains.
ACLCA2-18
3.2.D
B
PCRs that do not prescribe specific secondary datasets shall require that EPDs
disclose the name, source reporting period, publication date and version associated
with any secondary data used in the resulting EPD.
This criterion supports the
disclosure of collected data for
end-user
comparability/verification.
3.2.E
B
Effective January 1, 2026, the PCR shall require that EPDs use facility-specific data
for any upstream input that individually contributes 75% or more to the disclosed
GWP-100 in the aggregated A1-A3 information modules,16 as identified by the LCA
produced for the PCR or reference LCA, unless no such specific data are available in
the current market.
AC LCA 2-25
3.2.F
B
Effective January 1, 2026, the PCR shall provide conservative17 default values
(including supportingjustification from the LCA produced for the PCR) for scenario
data of the specified processes where no data are available for the EPD developer. No
values should be left blank or n/a (not applicable).
AC LCA 2-28
16 The term "GWP" is used in EPDs, PCRs, and Buy Clean policies for construction products as an impact category to report on embodied GHG emissions (per ISO 21930:2017,
Section 7.3, Table 5). In the ISO context, "GWP" is conveyed in C02e/unit of product/material to denote the product level GHG emission intensities. We note this usage is
inconsistent with how GWP is defined by the Intergovernmental Panel on Climate Change (IPCC) and in other GHG accounting efforts, including national reporting by Parties to
the Paris Agreement. Per IPCC, GWP is an index measuring the radiative forcing following an emission of a unit mass of a given substance, accumulated over a chosen time
horizon, relative to that of the reference substance, carbon dioxide (C02). For more information on the definition and use of the term, "GWP" (Global Warming Potential), please
see https://www.epa.eov/eheemissions/understandine-global-warmine-potentials.
17 A conservative default value is one in which the PCR committee selects the worst yet realistic value after evaluating all available data (from domain-specific
experience and results from the LCA produced for the PCR or referenced).
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
Label Program for Low Embodied Carbon Construction Materials
Criteria #
B/L
Criterion
AC LCA PCR Guidance/ISO/
References
3.2.G
B
The PCR shall outline a list of primary data sources, secondary data sources and
default LCIA method(s) such that it is clear which flows are to be modeled using
which data source. This should take the form of a chart for end users to read and
apply. EPA recommends including a chart with the characteristics shown in Table G-1
of Appendix G.
AC LCA 2-31. Appendix G
Section 3.2—Leadership Criteria
3.2.H
L
The LCA produced for the PCR should include a complete DQA for both primary and
secondary data using EPA's DOA Methodology.
ACLCA 2-22;
ISO 21930:2017 Clause 7.1.9;
ISO 14044:2006 Clause 4.2.3.6;
ISO 14025:2006 Clause 6.7.2;
ISO/TS 14027:2017 Clause 6.2
3.2.1
L
The PCR should require the inclusion of a data source disclosure chart for EPDs such
that it is clear which flows were modeled using which data source (i.e., a specific
secondary set). This should take the form of a chart for end users to read and apply.
EPA recommends including a chart with the characteristics shown in Table G-2 of
Appendix G.
Note: This chart should not include confidential information, and should only list the
data source, such as a product- and facility specific EPD, or a specific secondary
dataset.
This criterion will aid in
comparability of EPDs by ensure
that EPDs reflective of products
that meet the same functional
use can be compared through
aligned data sources for the
foreground system modeling.
3.2.J
L
The PCR should require that EPDs use facility-specific data for any upstream input
that individually contributes 50% or more to the disclosed GWP-100 in the aggregated
A1-A3 information modules,18 as identified by the LCA produced for the PCR the
underlying or reference LCA that supports and aligns with the scope of the PCR,
unless no such specific data are available in the current market.
ACLCA 2-25
18 See footnote 16.
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Criteria #
B/L
Criterion
ACLCA PCR Guidance/ISO/
References
3.2.K
L
The PCR should identify and prescribe relevant upstream PCRs for use in the
modeling of impact of constituent products within the scope of the PCR being
establish and/or updated.
This criterion will help aid the
upstream and downstream
harmonization of PCRs.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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3.3 Facility Emission Data Specification
Criteria #
B/L
Criterion
ACLCA PCR Guidance/
References
3.3.A
B
Effective January 1, 2026, the PCR shall specify that industry average EPDs shall
follow ISO 21678:2020 for reference values type of benchmark and shall, at a
minimum:
a. Include the minimum scope of life cycle stages required by the PCR, and
provide the data by informational modules separately (e.g., A1, A2, A3).
b. Define similar product types19 and provide the rationale for such product
types within the product category.
c. Discuss market coverage for representativeness.
d. Where feasible and practical, benchmarks should be production volume
weighted, in other words, reflect a combination of the LCIA indicators of a
product and the amount of the product used. It is recommended to use and
average from one to three years of production volumes.
e. Include a statistical analysis, including the mean, standard deviation,
median, quintile distribution, level of confidence (including margin of error),
and confidence interval for the LCIA indicators outlined in Table 5 of ISO
21930:2017. This would include the number of data points (sample size)
used in the calculation of the statistical analysis per product type
identified. Additionally, the industry average EPD should explicitly state
which statistical distribution (e.g., normal, exponential) is being used to
derive the confidence interval and a justification for use of that distribution.
The industry average EPD should also include a description of the effect of
any missing data on the results.
The PCR shall include the methodology for developing industry average EPDs that
addresses how collected data from participating parties are to be aggregated using
ISO 21678:2020;
ISO 21930:2017, Clause 5.2.1, 7.3,
Table 5
This criterion helps ensure a
standardized industry average
methodology across sectors. This
supports public agency staff
workingwith multiple materials
within a construction project.
19 Similar product types are defined as materials/products within the same product category (e.g., concrete, glass, asphalt mixture, steel) that meet the same
requirements (function and/or performance). Product category refers to the group of construction products, construction elements, or integrated technical systems
covered under the PCR.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Criteria #
B/L
Criterion
ACLCA PCR Guidance/
References
a weighted average (vertical or horizontal) approach. Any disaggregation of impact
indicators regionally should be accompanied in the industry average EPD with an
explanation on how regional boundaries were determined.
3.3.B
B
The PCR shall provide guidance on how to cover purchasing and use of EACs,
specifically for procuring electricity via RECs for facility emissions reporting. As part
of the PCRs guidance, the PCR may also, but is not required to, consider the
following:
a. Determine the renewable share at the corporate, facility or product level.
b. Identify the facility/facilities and product(s) to apply contractual
instruments to and determine annual production volumes.
c. Determine whether the contractual instrument is applicable.
d. Use a balance sheet to allocate contractual instruments to annual
production.
e. Model allocated electricity covered by RECs.
f. Model allocated electricity not covered by RECs using a consumption grid.
g. Retire the RECs and ensure the reported GWP20 does not differ more than
10% for the duration of the EPD validity.
The PCR may consider following Criterion 3.3.F and Appendix D from EPA. or
ACLCA's Guidance for Quantifying Renewable Electricity Instruments in
Environmental Product Declarations (EPDs) from May 2023.
ACLCA's Guidance for Quantifying
Renewable Electricity Instruments
in Environmental Product
Declarations (EPDs) from May 2023
20 See footnote 16.
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Criteria #
B/L
Criterion
ACLCA PCR Guidance/
References
Section 3.3—Leadership Criteria
3.3.C
L
The PCR should require the EPD to disclose the ENERGY STAR Energy Performance
Score in the additional environmental information section of the EPD when an
Energy Performance Indicator is available for the manufacturing plant(s) in which
the product or constituent upstream product was manufactured.
Note: See Appendix C for recommended text to include in PCRs to address this
criterion.
ACLCA 2-25
For more information on how the
ENERGY STAR Score differs from
embodied carbon visit the consult
the ENERGY STAR Energy
Performance Score Fact Sheet.
For information on how to obtain a
score visit
www. e n e rgysta r. gov/e pis.
3.3.D
L
If facility-specific data are not available for the upstream unit processes, and such
a facility is required to report to EPA's GHGRP The PCR should require the EPD to
disclose in its additional environmental information section the carbon intensity of
the manufacturing plant (e.g., GHGs emitted per metric ton of product
manufactured) from which the product types, and/or the quartile21 in which the
manufacturing plant resides. Carbon intensity shall be calculated by dividing the
emissions reported to EPA's GHGRP by plant production. Emission and production
data must be from the same reporting period using the most recent year of data.
ACLCA 2-25
21 Quartile benchmarks exist for the following materials:
• Cement: https://www.epa.gov/svstem/files/documents/2021-10/cement-carbon-intensities-fact-sheet.pdf
• Flat glass: https://www.epa.gov/svstem/files/documents/2022-06/2019%20Flat%20Glass%20Plant%20Carbon%20lntensities%20Fact%20Sheet.pdf
• Fiberglass insulation: https://www.epa.gov/svstem/files/documents/2022-
06/2019%20Fiberglass%20Plant%20Carbon%20lntensities%20Fact%20Sheet%20.pdf
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Criteria #
B/L
Criterion
ACLCA PCR Guidance/
References
3.3.E
L
The PCR should require that the pre-consumer and post-consumer recycled
content of a product be separately disclosed in the EPD. Further, the PCR should
require that the allocation method used for recycling be disclosed in the EPD.
Note: See Appendix H for recommended text to include in PCRs to address this
criterion.
ISO 21930:2017, Clause7.2.4,
7.2.6;
ASTM E3199-22;
See Appendix H for more
information.
3.3.F
L
The PCR should provide guidance on how to cover purchasing and use of EACs,
specifically for procuring electricity via RECs for facility emissions reporting. PCRs
should require that:
• For manufacturing plants located in the United States, only EACs generated
from sources in the United States may be used.
• EACs accounted in the LCA must be the same reporting period as the
reporting period for other energy data.
• EACs come from generators that were placed into service within the past
15 years.
• The electricity accounting methodology (location-based versus market-
based) be disclosed on the EPD when presenting the LCA results.
• A manufacturer must attest in writing that EACs allocated to a particular
facility or product have and will not be sold or transferred after a claim has
been made. A manufacturer must document controls it has put in place to
manage EAC allocation within its operating boundary.
• In cases where EACs are retired on behalf a specific facility or for a
manufacturing process within a facility, an EAC retirement report, which
references the manufacturing facility's name, must be produced which
references the manufacturer's name in the retirement report and
documentation related to the EAC allocation within the manufacturers
operational footprint must be produced and verified.
See Appendix D for more
information on EACs and RECs.
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Criteria #
B/L
Criterion
ACLCA PCR Guidance/
References
• EAC-based electricity must use LCI data based on the same LCI models
used for grid electricity. Facility-specific generation models should be
employed to match the carbon intensity of the EAC electricity generators. If
facility-specific models are not available, regional models of the same
energy source generation type may be used. The same values for grid line
losses used in the electricity grid LCI shall be applied to EAC-based
electricity LCIs.
• The EPD verifier must verify that the manufacturer owns the EACs and has not
sold or transferred them after a claim against them has been made.
• EACs with Green-e certification (or another EPA-approved EAC
certification) must be used when EACs are included in the calculation of
life cycle impacts.
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Appendix A: Overview of EPA's Efforts to Improve
Free-to-Use and Publicly Accessible Secondary
Datasets within the United States
Throughout EPA's PCR Criteria, there are multiple references to the use of free-to-use and publicly
accessible secondary datasets for PCRs that cover the United States. As part of this effort, EPA has
outlined the risks associated with the use of proprietary datasets (see Appendix F of this document).
While these challenges are present, so are the concerns associated with the existing state of free-to-
use and publicly accessible secondary datasets, primarily in reference to those found within the U.S.
Federal LCA Commons. As part of EPA's efforts to implement Sections 60112 and 60116 of the Inflation
Reduction Act of 2022, EPA is committed to improving and directly investing in free-to-use and publicly
accessible datasets for reference in PCRs. These efforts have already begun over the course of 2024,
with EPA undertaking multiple different efforts to address the existing data gaps and useability concerns
associated with the FLCAC. As such, EPA is providing multiple documents (many of which are
referenced within the PCR Criteria) to aid in the outline of efforts that EPA is taking, and efforts relating
to data quality within PCRs. All the documents listed below are published on EPA's website and will
provide context for efforts associated with the improvement of the FLCAC.
• A Vision and Plan to Improve Secondary Life Cycle Assessment Data Used in Environmental
Product Declarations
• Memorandum of Understanding Among the U.S. Department of Energy (DOE), U.S. Environmental
Protection Agency (EPA), U.S. Department of Agriculture (USDA), U.S. Department of
Transportation (DOT), and the National Institute of Standards and Technology (NIST) on the
Federal Life Cycle Assessment (LCA) Commons
• Life Cycle Inventory Data Gap Assessment
• Data Quality Assessment Method for Secondary Data to Support the Label Program for Low
Embodied Carbon Construction Materials (Version 1) (EPA's DOA Methodology)
• Data Quality Assessment Method Template (Version 1)
• Product Category Rule Standards and Related Initiatives
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Appendix B: List of Criteria
Baseline List of Criteria
Baseline, Effective
Leadership
January 1, 2026
1.1.A
1.2.B (see note)
1.1.1
1.1.B
1.2.C (see note)
1.1.J
1.1.C
1.2.D (see note)
1.1.K
1.1.D
3.2.A
1.2.E
1.1.E
3.2.B (see note)
1.2.F
1.1.F
3.2.E
1.2.G
1.1.G
3.2.F
2.1.0
1.1.H
3.3.A
2.1 .P
1.2.A
3.1 .D
1.2.B
3.2.H
1.2.C
3.2.1
1.2.D
3.2.J
2.1.A
3.2.K
2.1 .B
3.3.C
2.1 .C
3.3.D
2.1 .D
3.3.E
2.1 .E
3.3.F
2.1 .F
2.1 .G
2.1 .H
2.1.1
2.1.J
2.1 .K
2.1 .L
2.1 .M
2.1 .N
2.2
3.1.A
3.1 .B
3.1 .C
3.2.B
3.2.C
3.2.D
3.2.G
3.3.B
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Appendix C: Recommended Text Associated with
ENERGY STAR
The U.S. EPA's ENERGY STAR program facilitates several activities recognizing companies and plants
that have noteworthy accomplishments in managing and reducing energy use in their operations.
Reducing energy use is a primary method of reducing carbon dioxide emissions, particularly if on-site
fuel consumption is minimized. EPA recommends the following text be included in PCRs:
Recommended Text Associated with Criterion 1.1.1
Plant Certification
The U.S. Environmental Protection Agency (EPA) provides ENERGY STAR certification to manufacturing
plants that are the most energy efficient plants in their sector. An http://www. energvstar. gov/plants is in
the top quartile of energy efficiency, when compared to similar plants and often emits less carbon
dioxide than similar plants. ENERGY STAR Certified Plants are subject to additional criteria defined in
the ENERGY STAR program and verification by EPA.
An EPD may indicate whether a plant in the associated product's supply chain has achieved Plant
Certification within the allowable EPD data collection period. The following information shall be
provided:
• Plant name and location.
• The year(s) in which the refinery achieved ENERGY STAR certification.
• Website link to a www.epa.gov or www, energvstar. gov webpage that shows whether a plant has
achieved ENERGY STAR certification. The recommended link at the time of publishing this PCR is
https://www.energystar.gov/buildings/certified buildings and plants.
Challenge for Industry
The ENERGY STAR http://www. energvstar. gov/industrvchallenge recognizes manufacturers that have
achieved a reduction of 10 percent or more in energy intensity within a five-year period.
An EPD published under this PCR may indicate that the manufacturing plant(s) has achieved the
ENERGY STAR Challenge for Industry within the allowable EPD data collection period. If so, the following
information shall be provided:
• Facility name and location.
• The year in which the Challenge for Industry was achieved.
• The percent reduction in energy intensity that was achieved.
• Website link to www.epa.gov or www, energvstar.gov webpage that shows whether a plant has
achieved the Challenge for Industry. The recommended link at the time of publishing this PCR is
https://www. energvstar. gov/industrial plants/earn-
recognition/energv star challenge industry2/challenge-achieved.
Partner of the Year Award
U.S. EPA Partner of the Year Award recipients are businesses recognized by EPA for havingmade
outstanding contributions to protecting the environment through superior energy efficiency
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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achievements, documented proven energy savings, and established a corporate energy management
program that encompasses key elements identified by ENERGY STAR.
An EPD published under this PCR may indicate that the company that owns the manufacturing plant(s)
has achieved the ENERGY STAR Partner of the Year Award within the allowable EPD data collection
period. The following information maybe provided:
• The year(s) in which the ENERGY STAR Partner of the Year Award was achieved.
• Website link to a www.epa.gov or www, energvstar. gov webpage that shows whether a company
has achieved the Partner of the Year Award. The recommended link at the time of publishing this
PCR is https://www.energystar.gov/about/how-energy-star-works/our-partners/awards.
Recommended Text Associated with Criterion 3.3.C
ENERGY STAR Score
EPA has developed ENERGY STAR Energy Performance Scores to benchmark the energy efficiency of
certain manufacturing plants. Energy Performance Scores measure how energy efficient a
manufacturing plant's operations are when compared to similar plants and uses a 1-100 scale to score
the plant's energy performance. A score of 50 reflects average performance, 1 reflects lowest
performance, and 100 reflects highest performance.
The ENERGY STAR Score must be reported for the [select all that are applicable to the product's supply
chain: integrated steel mill, flat/float glass manufacturing facility, cement plant, [and] asphalt mix plant]
in the product's supply chain using the following format:
• Name and location of manufacturing plant: [name of manufacturing plant; city, state]
• ENERGY STAR Score:r##]
• Reporting period: [month/year-month/year]
¦ ENERGY STAR Scores are based on 12 consecutive months of energy- and production-related
data. This field discloses the 12-month period of data used to determine the ENERGY STAR
Score. The reporting period, to the extent possible, should align with the data period used for
producing the EPD or include a more recent 12-month period.
• EPI model version: [version x.xyear]
¦ The model used to calculate ENERGY STAR Scores is periodically updated. Include the version
number found at the top of the Energy Performance Indicator used to calculate the score.
• ENERGY STAR Certification (if applicable): [Certification year(s)]
Note: At the time of publication, EPIs are available for integrated steel mills, float/flat glass
manufacturing plants and cement plants. An EPI is being developed for asphalt mix plants. This section
will be updated as EPIs are developed for additional industrial sectors.
For more information on how to obtain a score visit the webpage:
https://www.energystar.gov/industrial_plants/measure-track-and-benchmark/energy-star-energyFor
more information on how the ENERGY STAR Score differs from embodied carbon visit the webpage:
https://www.energystar.gov/buildings/tools-and-resources/disclosing-energy-star-score-low-
embodied-carbon-programs
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Appendix D: Additional Information on EACs and RECs
Technical Considerations
Energy attribute certificates are contractual instruments that convey information (i.e., attributes) about
a unit of energy, including the resource used to create the energy and the emissions associated with its
production and use.22 EACs can take a variety of forms, including renewable energy certificates, zero-
emissions credits and renewable thermal certificates. EACs are used throughout the renewable energy
economy to substantiate claims related to corporate GHG reporting, contractual mechanisms for
renewable electricity purchases (e.g., power purchase agreements) and other programs.
Note that these criteria are written in the context of renewable electricity and the related energy
instruments, such as RECs, used in the U.S. market to verify contractual claims of electricity use. The
criteria do not address the use of EAC applications related to direct fuel use or non-renewable sources
of energy.
The Greenhouse Gas Protocol is a widely accepted international framework for emissions accounting.
The protocol comprises a set of standards and guidance also known as scope 2, and includes guidance
on accounting for emissions associated with purchased electricity. Under the protocol's scope 2
guidance, companies are required to account for their emissions using two separate methods, referred
to as dual reporting.23 The first method, the location-based method, seeks to account for a company's
emissions based on where the company's electricity consumption occurs. The second method, the
market-based method, seeks to account for emissions associated with the contractual choices a
company makes for specified sources of electricity. The market-based method relies on market-based
instruments, such as EACs, to verify a consumer's contractual procurement of electricity from specified
resources. EACs are an internationally accepted mechanism for allocating generation across a shared
electricity grid and for representing the emissions associated with electricity. In other countries, EAC
instruments may be referred to by different names. For example, a REC is a type of EAC produced from
renewable resources.
The type of accounting methodology used determines the amount of embodied carbon disclosed in an
EPD and the data on which public agencies will base decisions. LCAs and EPDs have only recently
started following the conventional approach of using location-based accounting of electricity
emissions. The demand for lower embodied carbon materials has prompted the market to consider
additional pathways, including procuring renewable electricity, to distinguish their products and
account for their investments in carbon disclosures. While standards and guidance exist for reporting
renewable electricity at the organizational level, there has been less focus on developing an approach
for incorporating renewable electricity into LCAs.
22 An EAC is a contractual instrument that conveys information (attributes) about a unit of energy, including the resource
used to create the energy and the emissions associated with its production and use. For more information, see
https://www.epa.gov/green-power-markets/energy-attribute-certificates-eacs and
https://www.epa.gov/system/files/documents/2024-02/energy attribute certificates.pdf.
23 Sotos, M. (2015). Section 1.5.1: New Reporting Requirements. In: GHG Protocol Scope 2 Guidance. World Resources
Institute, https://ghgprotocol.org/scope-2-guidance.
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EPA is supportive of current efforts to create renewable electricity guidelines for PCRs. ACLCA provides
guidance in its Open Standard addendum on Quantifying Renewable Electricity Instruments in
Environmental Product Declarations.24This addendum is being updated.
EPA has assessed current guidelines and prescribed additional requirements to ensure the
methodological integrity of incorporating market-based accounting in LCAs that support EPDs for EPA's
label program. These criteria are outlined in sections 1.1.1, 3.3.B and 3.3.F of EPA's PCR Criteria. This
appendix provides additional context and justification for these criteria.
In the long term, EPA envisions a standard and an accompanying conformity assessment protocol for
using EACs that informs market-based electricity accounting approaches in product-level LCAs. As the
practices for accounting for renewable electricity evolve, the standards related to EPDs will also have to
evolve. For example, a standard would need to consider the emerging trend toward more granular
matching of generation to consumption through schemes such as 24/7 hourly matching.25
In the interim, for methodological consistency within PCRs and EPA's label program, a consistent
approach should be used when calculating electricity emissions.
Criteria from Section 3.3.F
Practices for calculating renewable electricity in EPDs are expected to conform with corporate
accounting standards, scope 2 guidance, and best practices when applicable.
Purchase of Electricity Within Market Boundaries
• Criterion: For manufacturing plants located in the United States, only EACs generated from
sources in the United States may be used.
• Justification: EPA expects that EACs will be generated in the same market where electricity
consumption occurs. Furthermore, EPA expects that the market boundary will be defined based
on a regulatory and legal basis that prevents double counting. Currently, some programs and
policies define North America as a single market, including the ACLCA Open Standard (Section
2.2.1 of Quantifying Renewable Electricity Instruments in Environmental Product Declarations).
However, unlike the European Union and its member states,26 the United States, Canada and
Mexico do not have a compact in place to provide reciprocal acknowledgement of EACs across
national boundaries. The lack of reciprocal acknowledgement presents a potential for double
counting. Therefore, EPA expects that manufacturers only purchase EACs from within the United
States to serve consumption occurring in the United States. This conforms with EPA's
interpretation of international standards and guidance related to scope 2 accounting27 of
purchased electricity as well as other federal policy positions.28 Trends in the market indicate
24 American Center for Life Cycle Assessment. (2023). Guidance for Quantifying Renewable Electricity Instruments in
Environmental Product Declarations (EPDs). https://aclca.org/wp-content/uploads/2022-ACLCA-PCR-Qpen-
Standard Addendum Ouantifying-Renewable-Electricity-lnstruments-in-EPDs FINAL 061323.pdf.
25 U.S. EPA. (February 6, 2024). 24/7 Hourly Matching of Electricity, https://www.epa.gov/green-power-markets/247-
hourly-matching-electricity.
26 European Union members are directed through the Measuring Instruments Directive (MID) and European standards
that define the cooperation between European member states, https://single-market-economy.ec.europa.eu/single-
market/european-standards/harmonised-standards/measuring-instruments-mid en and https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0944&qid=1721059062914.
27 International standards and guidance: https://ghgprotocol.org/scope-2-guidance.
28 Federal policy positions: https://www.epa.gov/sites/default/files/2020-12/documents/electricityemissions.pdf and
https://www.epa.gov/sites/default/files/2016-01/documents/gpp partnership reqs.pdf.
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that generation matched to consumption on a geographical basis may become more narrowly
aligned within international accounting and reporting standards, which would require future
adjustments under this requirement.
Temporal Reporting Eligibility of Generation Matched to Consumption
• Criterion: EACs accounted for in the LCA must have the same reporting period as the reporting
period for other energy data.
• Justification: The GHG Protocol Scope 2 Guidance explains that the contractual instruments
used shall "be issued and redeemed as close as possible to the period of energy consumption to
which the instrument is applied."29 For EPDs, EPA expects that electricity reported under a 12-
month reporting period must be generated during that reporting period. Trends in the market
indicate that electricity generation and consumption should match with regard to when and
where they occurred.
Vintage Eligibility of Generators
• Criterion: EACs come from generators that were placed into service within the past 15 years.
• Justification: EPA expects that all generation comes from generators that were placed into
service within the past 15 years. This expectation aligns with the ACLCA renewable electricity
addendum and Green-e Framework for Renewable Energy Certification.30 This eligibility period
supports a term of contract that allows projects and project investors ample time to recoup their
investments through a supply contract. Standards that are developed to address EACs in LCAs
may establish a newer generator vintage date. However, these standards should consider a
grandfathering clause beyond the eligibility date such that the generation in the out years of the
contract is eligible for the manufacturer. Trends in the market suggest that the eligibility of vintage
generators may also change as the term for a return on investment decreases, which would
require future adjustments under this requirement.
Disclosure of Accounting Methodology
• Criterion: The electricity accounting methodology (location-based versus market-based) shall be
disclosed on the EPD when presenting the LCA results.
• Justification: There is no standardized terminology used in EPDs for characterizing the
methodology when EACs are or are not accounted for in the calculation of LCI results. To align
with other accounting methodologies, EPA recommends that the terms "location-based" and
"market-based" accounting be used. These terms should be used on the EPD to describe the
electricity accounting methodology used. Definitions are as follows:
• Location-based accounting: A method to quantify scope 2 GHG emissions31 based on average
energy generation emission factors for defined locations, including local, subnational or national
29 World Resources Institute. (2015). Greenhouse Gas Protocol Scope 2 Guidance: An Amendment to the Greenhouse
Gas Protocol Corporate Standard. https://ghgprotocol.org/sites/default/files/2023-03/Scope%202%20Guidance.pdf.
30 Green-e. (2017). Green-e Framework for Renewable Energy Certification. Version 1.0. https://www.green-
e.org/docs/energy/framework/Green-e%20Framework%20for%20Renewable%20Energy%20Certification.pdf.
31 "Scope 2 emissions" refers to the indirect emissions from a reporting entity's generation and consumption of
purchased or acquired electricity, steam, heat or cooling.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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boundaries. This definition is consistent with the one in the Scope 2 Standard of the GHG
Protocol.
• Market-based accounting: A method to quantify scope 2 GHG emissions based on GHG
emissions emitted by the generators from which the reporter contractually purchases electricity
bundled with instruments, or unbundled instruments on their own. This definition is consistent
with the one in the Scope 2 Standard of the GHG Protocol.
All purchased electricity used in corporate manufacturing activities should align with the electricity
purchased and reported under scope 2 corporate accounting practices.
Allocation Documentation
• Criteria: A manufacturer must attest in writing that EACs allocated to a particular facility or
product have not been and will not be sold or transferred after a claim has been made. A
manufacturer must document controls it has put in place to manage EAC allocation within its
operating boundary.
• Justification: The ACLCA renewable electricity addendum requires that LCA reports include a
balance sheet to allocate contractual instruments to annual production. It permits EACs to be to
the entirety or a portion of a facility's production volume. EPA will be developing a white paper on
best practices in allocating EACs within a corporate footprint and verification recommendations,
which can enhance existing EAC accounting efforts. Because corporations often buy renewable
electricity at a corporate level, a credible and transparent process for allocating EACs within a
corporate operational footprint will be necessary and to avoid double counting. EPA also
recommends the creation of a standard and accompanying conformity assessment protocol for
using EACs that inform market-based electricity accounting approaches in product-level LCAs. In
the interim, manufacturer allocation procedure documentation provides transparency and a
paper trail outlining EAC allocation. Such documentation should explain how an organization will
guarantee that the EACs being attributed to a product in the EPD will not be attributed to other
products or activities and describe what internal accounting controls have been put in place.
Facility-Specific Allocation
• Criterion: In cases where EACs are retired on behalf a specific facility or for a manufacturing
process within a facility, an EAC retirement report, which references the manufacturing facility's
name, must be produced. Documentation related to the EAC allocation within the
manufacturer's operational footprint must also be produced and verified.
• Justification: An organization owns an EAC, and EACs are retired by organizations, not products.
EAC retirement reports can indicate whether the EAC was retired for a particular facility.32 These
retirement reports are not set up to indicate whether they are associated with a particular
product. In the interim, manufacturers who intend to include EACs in embodied carbon
accounting are expected to name the facility as part of the retirement process. Tracking systems
provide customizable "notes" fields so users can identify the intent of allocation in an EAC
32 Procurement of clean electricity through retail programs, products or tariffs may not be able to produce retirement
reports that allocate specific EACs to customers or verify retirement to a specific manufacturer facility. In these cases,
purchasingthird-party-certified products ensures that the manufacturer has had EACs retired on its behalf. In some
cases, the verification and allocation of EACs may need to be documented outside of EAC tracking system reports.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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retirement report. EAC ownership and retirement can be demonstrated through the following
means:
¦ A purchase contract between the supplier and the manufacturer detailing conveyance or
ownership of the associated EACs (if the EACs are not self-generated)
¦ A tracking system EAC retirement report that includes:
° Documentation that the EACs were retired for the manufacturer
° A notation in the tracking system of the EAC's intended allocation to the manufacturer's
operational footprint
Tracking system retirement processes provide a field for the EAC owner to indicate the "retirement
reason," which can be used for naming the facility. This field is editable. See an example of this field in
Figure D-1 below.
If the intended allocation of EACs cannot be noted in the retirement report, the manufacturer will have
to provide this documentation separately, including EAC unique identification numbers, so a verifier
can ensure that EACs are not double claimed.
Transaction Confirmation M-RETS
Renewable Electricity
Date: 11-28-2022
M-RETS Organization: Admin REC Organization
Retiring 25318 active RECs
Account
ID
Project
Fuel Type Vintage
Location Quantity
Serial Number
My wind account I
1227D108-A04E
Agg Generator 2
Wind [2019-04-01 |
ND 115743 |
111114-ND-04-2019-CBBBFD6F-1 -15743
My wind account I
1227D108- ACME
Agg Generator 2
Wind 12021-01 -01 |
ND |9575
111114-ND-01 -2021-9B53EA2C-1 -9575
Retirement reason:
Beneficial Ownership - For Environmental Benefit
Retirement reason details:
Notes: EPA Example Test
to this retirement account
Retirement account 1
Figure D-1. Example EAC Retirement Report.
Aligning with an LCI
• Criteria: EAC-based electricity must use LCI data based on the same LCI models used for grid
electricity. Facility-specific generation models should be employed to match the carbon intensity
of the EAC electricity generators. If facility-specific models are not available, regional models of
the same energy source generation type may be used. The same values for grid line losses used in
the electricity grid LCI shall be applied to EAC-based electricity LCIs.
• Justification: An EAC retirement report is not formatted to contain all the relevant information to
be consumable in an LCA. As such, a protocol for associating the carbon intensity of an EAC to an
LCI is needed to ensure consistent application of EACs within LCAs.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Verification of Consumed Generation
• Criterion: The EPD verifier must verify that the manufacturer owns the EACs and has not sold or
transferred them after a claim against them has been made.
• Justification: Manufacturers making private investments in renewable electricity sources should
be able to claim those private investments in specified electricity sources using available market-
based accounting approaches. EPA expects that a manufacturer's claims of consumption from
specific generating sources must be verified and validated with EACs and reviewed by an
impartial third party involved in the verification of the EPD. This expectation aligns with
international standards and practices, such as the GHG Protocol, and meets U.S. FederalTrade
Commission guidance related to commercial marketing claims around the sale and use of
renewable electricity.33 The EPD verifier must verify that the manufacturer owns the EACs and has
not sold or transferred them after a claim against them has been made. This can be
demonstrated through the review of a clean electricity procurement contract supported by an
EAC retirement report. EAC tracking registries can also verify manufacturer EAC retirement and
claims. The documentation must match the assumed fuel pathways of the underlying LCA
analysis. The LCA verifier must also consider adding to the LCA report the circumstances (such
as increased electricity demand) under which the manufacturer must update the EPD to account
for a potential change in embodied carbon results.
Green-e
• Criteria: EACs with Green-e certification (or another EPA-approved EAC certification) must be
used when EACs are included in the calculation of life cycle impacts.
• Justification: Green-e-certified EACs34 ensure that the manufacturer is claiming use of
generation from resources that meet national standards for quality and content, the certifier has
validated that the purchase is backed by contracts, and EAC retirement has been executed. For
certain supply pathways related to retail renewable electricity programs and products, Green-e
certification is particularly important because an electricity content label is required to validate
specific fuel inputs to the LCA. EPA recommends Green-e as a consumer best practice. EPA's
ENERGY STAR Next Gen label, which has renewable energy procurement criteria, recognizes
Green-e as a pathway to validate the environmental attributes of RECs being applied to the
label.35 Manufacturers can also have bilateral, project-specific contracts certified under Green-e
Direct.
The next section of this appendix presents a set of questions that procurement agencies and users of
EPA's label program can ask EPD generators.
33 Federal Trade Commission. (October 11, 2012). Guides for the Use of Environmental Marketing Claims.
https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-guides/greenguides.pdf.
34 Center for Resource Solutions. (July 7, 2017). Green-e Framework for Renewable Energy Certification. Version 1.0.
https://www.green-e.org/docs/energy/framework/Green-
e%20Framework%20for%20Renewable%20Energy%20Certification.pdf.
35 U.S. EPA. (April 2024). Technical Reference: ENERGY STAR NextGen GHGi Targets.
https://www.energystar.gov/sites/default/files/2024-
04/Updated Technical Reference NextGen 04222024%20508C.pdf.
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Recommended Questions for Verifying and Auditing EPDs with EACs and Improving
Future Guideline Development
The following are recommended topics that an EPD or LCA verifier could include as part of their
verification of an EPD or LCA. These questions can also be used by a procurement program to audit
renewable energy procurement practices if the manufacturers are the same as those used to produce
an EPD submitted to their program. These questions are being provided for reference only and are not a
part of the baseline or leadership criteria.
• Obtain a copy of the LCA Report associated with the EPD.
¦ Per ISO 14025: 2006, "the independent verifier shall generate a report documenting the
verification process, while adhering to the obligations of 8.3 covering rules for data
confidentiality. This report shall be available to any person upon request."
• Confirm the inclusion of Table 3 from the ACLCA Open Standard addendum. See Figure D-2.
• In addition, verify the following information:
¦ The legal entity that procures and claims the EACs with electricity consumption is the same as
the entity reflected on the EPD.
¦ If EACs are allocated at the facility level, the facility name is noted in the EAC retirement report.
¦ The start and end dates of the 12-month period of reported energy consumption used in the LCA
align with the retirement report.
¦ That EACs come from generators that were placed into service within the past 15 years.
¦ Whenever the GWP36 is presented on an EPD, there is a note explaining whether location-based
or market-based accounting is used.
¦ EAC generation aligns with the same 12-month reporting period as electricity consumption.
¦ The reported generation of the EAC is from the same market as where electricity consumption
occurs. The maximum interpretation of the market boundary is the United States.
¦ The resource mix of a retail contract, between the "promise" and "actual" certification product
labels, has a variance of no more than 5 percent. This aligns with the Green-e National
Standard.
¦ Whether a reserve buffer to accommodate variable generation of overproduction and
underproduction exists.
¦ The proportion of EACs allocated to the specified manufacturing facility and product aligns with
the prescribed allocation methodology.
¦ EACs are Green-e certified, or another EPA-approved EAC certification is used.
¦ EAC-based electricity uses LCI data based on the same LCI models used for grid electricity.
¦ For any portion of electricity not covered by EACs, the LCI was used for modelling consumption
as appropriate.
36 See footnote 16.
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¦ The methodology the organization follows for allocating EACs across its plant and product
portfolio is documented and appropriate.
¦ The organization explains how it will guarantee that the EACs being attributed to the product in
the EPD will not be attributed to other products or activities. For example, an organization
should explain whether internal accounting mechanisms and controls have been put in place.
¦ Written documentation that the manufacturer will not allocate EACs to a particular facility or
product has not been and will not be sold or transferred after a claim has been made.
¦ The percentage of electricity consumed at the plant that is covered by EACs relative to total
annual electricity consumption of the plant is the same as the percentage in the published EPD
(if validating that renewable energy procurement practices have remained the same after an
EPD was published).
Ask the manufacturer to provide evidence that 1) the energy procurement contract with the vendor was
in effect for the energy and production data reporting period for conducting the LCA, 2) the contract is in
delivery status, and 3) the EACs have been retired for the reporting period of the EPD through the
present.
Ask the manufacturer to provide an EAC retirement report with a description of the allocation of EACs
within the corporate footprint to a particular facility and product line.
On an annual basis (or set schedule determined by the program), confirm that the purchase and
allocation of EACs proportional to production volume corresponds to the amounts and approach used
to allocate the EACs in the published EPD.
Table 3. Renewable energy certificate details for inclusion in the LCA background report
Renewable energy certificate technical scenario
Parameter
Unit
Value
Renewable generator project name:
Tracking system ID (unique generator ID):
Renewable facility/generator owner:
Renewable facility/generator location:
State / province
Project vintage (build date):
Year
Project generation date (year first produced renewable energy):
Year
Nameplate capacity of project:
MW
Certificate type:
Certificate unique ID:
Month and year of renewable energy generation:
Month / year
Month and year certificate issued:
Month / year
Utility to which the project is interconnected:
Figure D-1. Example EAC Retirement Report.
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U.S. EPA Criteria for Product Category Rules (PCRs) to Support the
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Appendix E: EPA's Recommended PCR Reviewer and
EPD Verifier Qualifications
EPA is establishing recommendations for PCR reviewer and EPD verifier qualifications. These
qualifications include independence and relevant competencies, such as industry- and product-
specific knowledge and knowledge of relevant standards related to LCA and EPDs. These
recommendations align with the requirements of ISO 14025:2006. Program operators responsible for
developing PCRs and/or EPDs are encouraged to adopt these recommended qualifications within their
General Program Instructions.
PCR Review Panel Qualifications
The PCR review panel shall be made up of at least three independent external experts. An independent
external expert is a competent person who is not employed (full-time or part-time) with the program
operator responsible for developing the PCR. The chair of the PCR review panel shall also be
independent of the industries producing and supplying the products covered by the product category or
their suppliers.
The combined competencies of the PCR review panel should include knowledge and proficiency in:
• Product and product-related environmental aspects for the relevant sector.
• LCA methodology and practice.
• The relevant standards in the fields of environmental declarations and LCA (i.e., ISO 14025:2006,
ISO/TS 14027:2017, ISO 14040:2006, ISO 14044:2006, ISO/TS 14071:2014 and ISO 21930:2017).
• The regulatory framework within the scope of the PCR.
• The EPD program(s) in which the PCR is intended to be used.
The program operator shall require each PCR review panel member to have a signed self-declaration of
reviewer independence and competencies (see example declaration on the next page).
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Example Declaration for PCR Review Panel Member
I, the signatory, hereby declare that:
• / am not a full-time or part-time employee of the program operator.
• / have not been involved in defining the scope or carrying out any of the work to develop the
product category rule (PCR) at hand (i.e., I have not been part of the PCR committee).
• / do not have a vested financial, political or other significant interest in the outcome of the PCR.
• If serving as the chair of the PCR review panel, I am not a full-time or part-time employee of a
manufacturer producing the products covered by the product category or of their suppliers.
My competencies relevant to the PCR review at hand include knowledge of and proficiency in (check
all that apply):
~ The product category that is the subject of the PCR and its associated environmental aspects.
~ LCA methodology and practice.
~ ISO 14025:2006, ISO/TS 14027:2017 and ISO 21930:2017.
~ ISO 14040:2006, ISO 14044:2006 and ISO/TS 14071:2014.
~ The regulatory framework within the scope of the PCR.
~ The environmental product declaration (EPD) program(s) in which this PCR is intended to be used.
I declare that the above statements are truthful and complete. I will immediately notify all parties
involved—including the program operator and other PCR reviewers, as applicable—if the validity of
any of these statements changes during the course of the review process.
Date:
Name (print):
Signature:
EPD Verifier Qualifications
The EPD shall be verified by a competent independent external EPD verifier. An independent external
verifier is a person who:
• Is not employed (full-time or part-time) with the commissioner or practitioner of the LCA study.
• Was not otherwise involved in the execution of the LCA that is used during development of the
EPD.
• Has not been otherwise involved in the development of the EPD.
The EPD verifier shall have competence in LCA and/or EPD development, indicated by evidence of
knowledge of the relevant sector, product and product-related environmental aspects as well as—at a
minimum—one of the following:
• Employment with (full-time or part-time) or contractual agreement with an organization that has
been accredited according to ISO 14025:2006 by an accreditation body that operates in
accordance with ISO/IEC 17011:2017 and is an International Accreditation Forum Multilateral
Recognition Agreement signatory for ISO/IEC 17029:2019 or ISO/IEC 17065:2012.
• ACLCA Life Cycle Assessment Certified Professional status, with two letters of reference.
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• Demonstration of five years of relevant LCA and/or EPD experience with two letters of reference.
The program operator shall require that the EPD verifier have a signed self-declaration of verifier
independence and competencies (see example declaration below).
Example Declaration for EPD Verifier
I, the signatory, hereby declare that:
• / am not a full-time or part-time employee of the commissioner or practitioner of the life cycle
assessment (LCA) study and was not otherwise involved in the execution of the LCA.
• / was not involved in the development of the environmental product declaration (EPD).
• I have no other conflicts of interest resulting from my position.
• / do not have a vested financial, political or other significant interest in the outcome of the LCA
study or EPD.
My competencies relevant to the EPD verification at hand include knowledge of and proficiency in:
• The sector, product and product-related environmental aspects associated with the product
addressed by the EPD.
• Process and product knowledge of the product category addressed by the product category rule
(PCR) used to develop the EPD.
• LCA methodology and practice.
• ISO 14025:2006, ISO 14040:2006, ISO 14044:2006, ISO/TS 14071:2014 and ISO 21930:2017.
• The regulatory framework within which the EPD has been prepared.
• The EPD program(s) under which this EPD is being developed.
I declare that the above statements are truthful and complete. I will immediately notify all parties
involved—including the organization developing the EPD and the EPD owner, as applicable—if the
validity of any of these statements changes during the course of the review process.
Date:
Name (print):
Signature:
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Appendix F: Reasoning for Preference of Use of Free-
to-Use and Publicly Accessible Datasets in LCAs
Federal Government Use of Standards
Consistent with Section 12(d) of the NationalTechnologyTransfer and Advancement Act and related
federal policies, federal government agencies like EPA have a long track record of participating in and
using standards developed through processes led by the private sector. See the EPA Voluntary
Consensus Standards website for additional information. Many of these private sector standards are
developed using procedures that have been accredited against the ANSI Essential Requirements. The
ANSI Essential Requirements help standards bodies demonstrate that their processes meet the criteria
for voluntary consensus standards. Section 12(d) of the NTTAA and related federal policies establish a
preference for using voluntary consensus standards in lieu of government standards.
The ANSI Essential Requirements also help prevent violation of U.S. antitrust law or other
anticompetitive behavior in developing standards. Of note is Article 3.2 of the ANSI Essential
Requirements, which addresses commercial terms and conditions. Article 3.2 generally prohibits
including terms or conditions that are primarily contractual or commercial in nature, as opposed to
technical, engineering or scientific in nature. Prohibited items include incorporating contractual
requirements (3.2.1); endorsing or requiring the use of proprietary products or services (3.2.2); or
endorsing or requiring the use of particular conformity assessment bodies, testing facilities or training
organizations (3.2.3). This prohibition against including commercial terms is echoed in competition law
guidelines published by ISO and the International Electrotechnical Commission.
EPA has a strong preference that the organizations developing PCR standards align their processes with
the attributes of voluntary consensus standards over the coming years. This preference is consistent
with Section 12(d) of the NTTAA and related federal policies, and with EPA's approach in the Framework
for Assessing Environmental Performance Standards and Ecolabels for Federal Purchasing. EPA
recognizes that doing so will take time, and that it may not be practical for all program operators and
PCR committees. However, at a minimum, it is essential that organizations developing PCR standards
comply with relevant antitrust and anticompetition laws. However, under any circumstances, it is
essential that organizations developing PCR standards comply with relevant antitrust and
anticompetition laws.
In addition to creating potential antitrust and anticompetition risks, having commercial terms in PCRs
could create risks for federal agencies seeking to use PCRs to support procurement decisions.
Risks to Federal Agencies When Commercial Terms (Including Proprietary
Datasets) Are Used in PCRs
The Inflation Reduction Act directed federal agencies to use EPDs to inform procurement of low
embodied carbon construction materials. However, federal agencies have a shared concern
surrounding the replicability of EPD results. These concerns all focus on EPDs that are associated with
materials and products that are directly purchased and directly delivered to federally funded
construction sites. When PCRs require the use of proprietary datasets, federal agencies are forced to
purchase access to the specified proprietary secondary datasets to accurately replicate results. To
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confirm manufacturer claims regarding embodied carbon of construction materials, federal agencies
follow PCRs, which are currently outlining three approaches associated with secondary datasets:
1. Prescription of proprietary datasets.
2. Prescription of public datasets.
3. No guidance on which specific datasets to use.
Risk of Prescription of Proprietary Datasets
• Contrary to ANSI Essential Requirements.
• Contrary to OMBA-119 and the NTTAA.
• Potentially contrary to the three major antitrust laws that affect standard setting (the Sherman
Act, the Clayton Act and the FederalTrade Commission Act).
• No standard to evaluate fitness of modeling (at the present time).
Risk of Prescription of Free-to-Use and Public Datasets
• Not consistently funded; however, EPA is entering into a nonfinancial commitment Memorandum
of Understanding with other agencies for the Federal LCA Commons.
• No standard to evaluate fitness of modeling.
Risk of No Guidance on Which Specific Datasets to Use
• Lack of consistency of EPD impact calculations, resulting in an inability to compare results for
threshold setting.
While the federal government has outlined challenges associated with commercial terms, it is the PCR
developers' responsibility to ensure their own compliance with U.S. antitrust law.
For more information on how EPA is addressing the concerns and risks associated with the prescription
of free-to-use and publicly accessible datasets, please see Appendix A. PCR program operators
interested in technical assistance in better aligning with voluntary consensus standards approaches
may contact EPA by visiting EPA's website.
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Appendix G: Recommended Charts to Include in PCRs
Appendix G.l: Recommended Data Disclosure Charts for PCRs
Below is an example data disclosure chart for secondary data sources specified in PCRs. This includes
the following considerations:
A. The specified secondary datasets shall be free-to-use and publicly accessible to all users of the
PCR in order to create EPDs.37 EPA will allow program operators to specify selected datasets
until January 1, 2026 (see Criterion 3.2.B for more information). After that date, the PCR must be
updated to prescribe EPA-designated public datasets for processes that occur within the
United States of America, where available.
B. Temporal, geographical and technological coverage of the secondary data shall be compatible
with the scope of the PCR.
C. System boundaries shall be equivalent, and reference flows shall be adaptable to the product
system specified in the PCR.
D. The secondary data's sources, year of publication and reporting period shall be cited.
E. Allocation procedures used for secondary data shall be appropriate for the system under study.
These specifications shall be tied to specific flows as outlined in bullet "C" above (system boundaries).
Furthermore, all flows shall be listed within comprehensive lists tied to each LCA module being
reported on under the scope of the PCR. These flows shall be identified via the LCA that supports and
aligns with the scope of the PCR.
EXAMPLE Table G-1. Data Disclosure Chart for Secondary Data Sources Specified in PCRs
Material/Process
Category8
Material/Process
Nameb
Secondary
Inventory
Dataset
Name0
Dataset
Geographic
Region6
Year
Dataset
Represents
Reference6
Transport
Transport Mode A
Exact
dataset
name
Most
granular
region
specified
and country
Year or
range of
years
Full
reference,
including LCI
database
version
number and
year; link to
underlying
public
dataset
Transport Mode B
37 EPA is actively working to improve free-to-use and publicly accessible datasets. At a minimum, this will include efforts
relating to electricity, fuels, and transportation flows. More information on how the federal government is investing in
improvements to free-to-use and publicly accessible datasets can be found in Appendix A and on EPA's website.
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Material/Process
Category8
Material/Process
Nameb
Secondary
Inventory
Dataset
Name0
Dataset
Geographic
Region6
Year
Dataset
Represents
Reference6
Energy
Material
a Add rows to include additional material/process categories.
b Add rows to include additional specifications for secondary LCI data.
c Specify the exact LCI dataset name as it appears in reference, e.g., "Transport, combination truck, long-haul, diesel
powered, Southeast."
d Specify the most granular region available and country (e.g., Southeast, United States). If country-level data are not
available, provide broader region (e.g., North America, global).
e Include year secondary dataset published and version number of dataset and LCI database (if available), e.g., U.S. Life
Cycle Inventory Database_2024_Q1_V1. National Renewable Energy Laboratory. Dataset available at:
https://www.lcacommons.gov/lca-
collaboration/National Renewable Energy Laboratory/USLCI Database Public/dataset/PROCESS/a17f251a-de94-
3933-b3b1 -61 aef7df590d.
Appendix G.2: Recommended Data Disclosure Charts for EPDs
Below contains an example data disclosure chart for data sources used to produce EPDs from their
relevant PCRs.
EXAMPLE: Table G-1. Data Disclosure Chart for Data Sources Used for Resulting EPDs
Module
Material/Unit
Data Source
Data Source
Geographic
Coverage
Year(s)
A1
Material A
Association X industry average
EPD
North America
2020
A1
Material B
Product- and facility-specific EPD
(include name)
Specific facility
2021
A1
Material C
LCI dataset for Y (provide dataset
name, version and process)
United States
2019
A2
Transportation
LCI dataset for Z (provide dataset
name, version and process)
United States
2018
A3
Production facility
emission source
Company X
Specific facility
2023
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Appendix H: Additional Information and
Recommended Text Associated with Recycled
Content Disclosure Requirements
EPA has determined through the development of the ReCon Tool and other research that there is a
correlation between the recycled content included in a product and the embodied carbon emissions
associated with that product, after accounting for pertinent factors such as material type, material
mass and regionality. EPA recommends that recycled content and the allocation approach used be
disclosed in EPDs to further investigate the correlation.
The following is recommended PCR text associated with Criterion 3.3.E.
The manufacturer will report the pre- and post-consumer recycled content for the product.
Differentiating between the two is important because sources, recovery methods, required
processing and associated impacts for pre- and post-consumer recycling will vary. Additionally,
post-consumer recycling supports diverting material from landfills and incineration since the
material would have otherwise reached its end use. Refer to the Terms and Definitions section
of this document for more on pre- and post-consumer recycled content.
The manufacturer will report whether the recycled content is facility specific, whether it has
been third-party verified and if so, under which standard.
The EPD must disclose which allocation approach was used.
In cases where an input from an upstream manufacturer contains recycled content, the percent
of recycled content for the product being reflected in the current EPD must be adjusted. For
example:
• A product is composed of 60 percent material input A and 40 percent material input B.
• Material input A contains 30 percent recycled content, and material input B contains 100
percent recycled content.
• Therefore, the recycled content percentage of the product can be calculated as follows:
(0.30 x 0.60) + (1.00 x 0.40) = 0.58 = 58%
If the percentage of recycled content for an upstream input cannot be determined, the user
must assume 0 percent recycled content for the upstream input. The results may be qualified as
"at least." For example:
• A product is composed of 60 percent material input A and 40 percent material input B.
• It is unknown how much recycled content is contained in material input A. Material input B
contains 100 percent recycled content.
• Therefore, the minimum recycled content percentage of the final product can be calculated
as follows:
(0.00 x 0.60) + (1.00 * 0.40) = 0.40 = 40%
• In other words, the product contains at least 40 percent recycled content.
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References
American Center for Life Cycle Assessment. (May 2019). ACLCA Guidance to Calculating Non-LCIA
Inventory Metrics in Accordance with ISO 21930:2017. https://aclca.org/aclca-iso-21930-
guidance/.
American Center for Life Cycle Assessment. (2023). Guidance for Quantifying Renewable Electricity
Instruments in Environmental Product Declarations (EPDs). https://aclca.org/wp-
content/uploads/2022-ACLCA-PCR-Qpen-Standard Addendum Quantifying-Renewable-
Electricity-lnstruments-in-EPDs FINAL 061323.pdf.
American Center for Life Cycle Assessment, (n.d.). Life Cycle Assessment Certified Professional
(LCACP). https://aclca.orE/lcacp-certification. Accessed February 8, 2024.
American National Standards Institute. (January 2024). ANSI Essential Requirements: Due Process
Requirements for American National Standards. https://www.ansi.orE/american-national-
standards/ans-introduction/essential-requirements.
Bhat, C.G., Adhikari, T., Mellentine, J., Feraldi, R., Lasso, A., Swack, T., Mukherjee, A., Dylla, H., &
Rangelov, M. (May 25, 2022). 2022 ACLCA PCR Guidance—Process and Methods Toolkit.
Version 1.0. American Center for Life Cycle Assessment, https://aclca.ors/wp-
content/uploads/2022-ACLCA-PCR-Guidance vl Introduction 05252022.pdf.
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Label Program for Low Embodied Carbon Construction Materials
Greenhouse Gas Protocol, (n.d.). Standards and Guidance, https://ghgprotocol.org/standards-
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Statements and Programmes for Products—Principles and General Requirements.
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and Declarations—Self-Declared Environmental Claims (Type II Environmental Labelling).
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International Organization for Standardization. (June 11, 2021). ISO 14025:2006—Environmental Labels
and Declarations—Type III Environmental Declarations—Principles and Procedures.
https://www.iso.org/standard/38131 .html.
International Organization for Standardization. (April 2017). ISO/TS 14027:2017—Environmental Labels
and Declarations—Development of Product Category Rules.
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International Organization for Standardization. (August 12, 2014). ISO 14040:2006—Environmental
Management—Life Cycle Assessment—Principles and Framework.
https://www.iso.org/standard/37456.html.
International Organization for Standardization. (August 12, 2014). ISO 14044:2006—Environmental
Management—Life Cycle Assessment—Requirements and Guidelines.
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International Organization for Standardization. (June 2014). ISO/TS 14071:2014—Environmental
Management—Life Cycle Assessment—Critical Review Processes and Reviewer
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https://www.iso.org/standard/61103.html.
International Organization for Standardization. (October 2019). ISO/IEC 17029:2019—Conformity
Assessment—General Principles and Requirements for Validation and Verification Bodies.
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International Organization for Standardization. (June 8, 2020). ISO/IEC 17065:2012—Conformity
Assessment—Requirements for Bodies Certifying Products, Processes and Services.
https://www.iso.org/standard/46568.html.
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Label Program for Low Embodied Carbon Construction Materials
International Organization for Standardization. (June 2020). ISO 21678:2020—Sustainability in Buildings
and Civil Engineering Works—Indicators and Benchmarks—Principles, Requirements and
Guidelines, https://www.iso.org/standard/71344.html.
International Organization for Standardization. (August 11, 2017). ISO 21930:2017—Sustainability in
Buildings and Civil Engineering Works—Core Rules for Environmental Product Declarations of
Construction Products and Services, https://www.iso.org/standard/61694.html.
National Technology Transfer and Advancement Act of 1995. Public Law, 104-113.
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Executive Departments and Agencies, https://www.whitehouse.gov/wp-
content/uploads/2017/11 /Circular-119-1 .pdf.
Secretariat of the Clean Energy Ministerial's Industrial Deep Decarbonization Initiative. (April, 2024).
Guidance of PCR Harmonization—Driving Consistency in Greenhouse Gas Accounting System
for Steel, Cement and Concrete Products. United National Industrial Development
Organization, https://www.industrialenergyaccelerator.org/wp-content/uploads/2404 IDDI-
Guidance-for-PCR-Harmonisation v1 O.pdf.
Sherman Anti-Trust Act of 1890. 26 Stat. 209, 15 U.S.C §§ 1.
https://uscode.house.gov/vi ew.xhtml:jsessionid=E90589FDE0E9E9B189962120D9F1135C?req
=granuleid%3AUSC-prelim-title15-
chapterl &saved=%7CZ3JhbnVsZWlkOlVTOy1wcmVsaWOtdGlObGUxNS1zZWNOaW9uMTI%3D
%7C%7C%7C0%7Cfalse%7Cprelim&edition=prelim.
Sotos, M. (2015). Section 1.5.1: New Reporting Requirements. In: GHG Protocol Scope 2 Guidance.
World Resources Institute, https://ghgprotocol.org/scope-2-guidance.
U.S. Department of Agriculture, (n.d.-a). Federal elementary flow list. Federal Commons LCA
Collaboration Server, https://www.lcacommons.gov/lca-
collaboration/Federal LCA Commons/elementary flow list/datasets. Accessed January 25,
2024.
U.S. Department of Agriculture, (n.d.-b). Publicly accessible datasets. Federal Commons LCA
Collaboration Server, https://www.lcacommons.gov/lca-collaboration/. Accessed January 25,
2024.
U.S. Department of Agriculture, (n.d.-c). US electricity baseline. Federal Commons LCA Collaboration
Server, https://www.lcacornmons.gov/lca-
collaboration/Federal LCA Commons/US electricity baseline/datasets. Accessed January 25,
2024.
U.S. EPA. (2011). Transport, Combination Truck, Long-Haul, Diesel Powered, Southeast [dataset].
Federal LCA Commons Collaboration Server, https://www.lcacommons.gov/lca-
collaboration/National Renewable Energy Laboratory/USLCI Database Public/dataset/PROC
FSS/a17f?51 a-de94-3933-b3b1 -61 aef7df590d.
U.S. EPA. (May 2019). EPA's Green Power Partnership: Partnership Requirements.
https://www.epa.gov/sites/default/files/2016-01 /documents/gpp partnership reqs.pdf.
U.S. EPA. (July 17, 2019). Recycled Content (ReCon) Tool. Waste Reduction Model.
https://www.epa.gov/warm/recycled-content-recon-tool.
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U.S. EPA. (October 2021). U.S. Cement Industry Carbon Intensities (2019). EPA430-F-21-004.
https://www.epa.gov/system/fiLes/documents/2021-10/cement-carbon-intensities-fact-
sheet.pdf.
U.S. EPA. (May 21, 2022-a). U.S. Flat Glass Industry Carbon Intensities (2019). EPA 430-F-22-006.
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06/2019%20Flat%20Glass%20Plant%20Carbon%20lntensities%20Fact%20Sheet.pdf.
U.S. EPA. (May21, 2022-b). U.S. Fiberglass Insulation Industry Carbon Intensities (2019) EPA430-F-21-
007. https://www.epa.gov/system/files/documents/2022-
06/2019%20Fiberglass%20Plant%20Carbon%20lntensities%20Fact%20Sheet%20.pdf.
U.S. EPA. (January 26, 2023). Request for Information (RFI) to Support New Inflation Reduction Act
Programs to Lower Embodied Greenhouse Gas Emissions Associated with Construction
Materials and Products. https://www.regulations.gov/docket/EPA-HO-OPPT-2022-0924.
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Electricity, https://www.epa.gov/sites/default/files/2020-
12/documents/electricityemissions.pdf.
U.S. EPA. (February 6, 2024). 24/7 Hourly Matching of Electricity, https://www.epa.gov/green-power-
markets/247-hourly-matching-electricity.
U.S. EPA. (February 15, 2024). Draft Approach for Stakeholder Input: Implementation of the EPA Label
Program for Low Embodied Carbon Construction Materials (Inflation Reduction Act 60116).
https://www.regulations.gov/document/EPA-HO-OPPT-2024-0038-00Q2.
U.S. EPA. (March 5, 2024). Draft Criteria for Product Category Rules to Support the Label Program for
Low Embodied Carbon Construction Materials; Notice of Availability, Webinar and Request for
Comment. Federal Register, 89 FR 15868.
https://www.federalregister.gov/documents/2024/03/05/2024-04593/draft-criteria-for-
product-category-rules-to-support-the-label-program-for-low-embodied-carbon.
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04/Updated Technical Reference NextGen Q4222024%2Q508C.pdf.
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LCIA-US) v0.1 [dataset]. https://catalog.data.gov/dataset/characterization-factors-for-
construction-material-epd-indicators-iso21930-lcia-us-v0-1
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rement and energy star 0. Accessed January, 25, 2024.
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assessment-environmental-performance-standards-and-ecolabels-federal.
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embodied-greenhouse-gas-emissions-construction-materials-and.
U.S. EPA. (n.d.-e). Greenhouse Gas Reporting Program (GHGRP). https://www.epa.gov/ghgreporting.
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Label Program for Low Embodied Carbon Construction Materials
U.S. EPA. (n.d.-f). ENERGY STAR Plant Certification, https://www.energystar.gov/industrial plants/earn-
recognition/plant-certification.
U.S. EPA. (n.d.-g). ENERGY STAR Challenge for Industry.
https://www.energystar.gov/industrial plants/earn-
recognition/energy star challenge industry2.
U.S. EPA. (n.d.-h). See Who Has Achieved the Challenge.
https://www.energystar.gov/industrial plants/earn-
recognition/energy star challenge industry2/challenge-achieved.
U.S. EPA. (n.d.-i). ENERGY STAR Awards, https://www.energystar.gov/about/how-energy-star-
works/our-partners/awards.
U.S. EPA. (n.d.-j). Buy Clean Procurement and ENERGY STAR.
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rement and energy star 0.
U.S. EPA. (n.d.-k). Registry of ENERGY STAR Certified Buildings and Plants.
https://www.energystar.gov/buildings/certified buildings and plants.
U.S. EPA. (n.d.-l). Voluntary Consensus Standards, https://www.epa.gov/vcs.
The White House. (May 2023). United States Government National Standards Strategy for Critical and
Emerging Technology. https://www.whitehouse.gov/wp-content/uploads/2023/05/US-Gov-
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Greenhouse Gas Protocol Corporate Standard.
https://ghgprotocol.org/sites/default/files/2023-03/Scope%202%20Guidance.pdf.
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Terminology
Allocation: Partitioning the input or output flows of a process or a product system between the product
system under study and one or more other product systems. This definition is consistent with the one in
ISO 14044:2006.
Byproduct: A coproduct from a process that is incidental or not intentionally produced and that cannot
be avoided. Note: Wastes are not byproducts. This definition is consistent with the one in ISO
21930:2017.
Construction material: The supplies used in building. This definition is consistent with the one in EPA's
Enterprise Vocabulary.
Coproduct: Any of two or more products coming from the same unit process or product system. This is
consistent with the definition in ISO 14044:2006.
Cradle-to-gate: A type of EPD regarding the life cycle stages covered in which the production stage is
reported on and includes the following A1 to A3 information modules: extraction and upstream
production (raw material supply), transport to factory, and manufacturing. This definition is consistent
with the one in ISO 21930:2017, Section 5.2.2.
Cradle-to-grave: A type of EPD regarding the life cycle stages covered in which the production stage (A1
to A3) and all the information modules from the construction stage (A4 to A5), use stage (B1 to B7), and
end-of-life stage (C1 to 04) are reported on. This definition is consistent with the one in ISO 21930:2017,
Section 5.2.2.
Declared unit: Quantity of a construction material used as a reference unit in an EPD based on an LCA
for the expression of environmental information needed in information modules. This definition is based
on the one in ISO 21930:2017.
Downstream PCR: A PCR that is covering a system or process carried out after the designated system
or process associated with the given PCR. This definition is based on the definition of the term
"Downstream Process" found in ISO 21930:2017.
End-of-life: The stage for a construction material that starts when it is replaced, dismantled or
deconstructed from the construction works and does not provide any further functionality. The end-of-
life LCA stage includes information modules C1 to C4. This definition is based on the one outlined in ISO
21930:2017.
Environmental product declaration (EPD): An environmental claim providing quantified environmental
data using predetermined parameters and, where relevant, additional environmental information. An
EPD also includes additional product and company information. This definition is consistent with the
one in ISO 14025:2006.
Foreground data: Data contained within the process(es) a manufacturer is modeling for its product
system.
Functional unit: The unit of comparison that assures that the products being compared provide an
equivalent level of function or service.
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Gate: The point at which a construction product or material leaves the factory before it becomes an
input into a subsequent manufacturing process or before it is transported to a distributor, another
factory or a construction site. This definition is consistent with the one in ISO 21930:2017.
Global Warming Potential (GWP): The term "GWP" is used in EPDs, PCRs, and Buy Clean policies for
construction products as an impact category to report on embodied GHG emissions (per ISO
21930:2017, Section 7.3, Table 5). In the ISO context, "GWP" is conveyed in C02e/unit of
product/material to denote the product level GHG emission intensities. We note this usage is
inconsistent with how GWP is defined by the Intergovernmental Panel on Climate Change (IPCC) and in
other GHG accounting efforts, including national reporting by Parties to the Paris Agreement. Per IPCC,
GWP is an index measuring the radiative forcing following an emission of a unit mass of a given
substance, accumulated over a chosen time horizon, relative to that of the reference substance, carbon
dioxide (C02). For more information on the definition and use of the term, "GWP" (Global Warming
Potential), please see https://www.epa.gov/ghgemissions/understanding-global-warming-potentials.
Gross GHGs: The total amount of greenhouse gases emitted into the atmosphere.
LCA produced for the PCR (underlying LCA): An LCA conducted during the establishment or update of
a PCR that aligns with the scope of the PCR and is used as the basis for claims and determinations
made within the PCR.
Life cycle: All consecutive and interlinked stages in the life of the object under consideration. This
definition is consistent with the one in ISO 21930:2017.
Life cycle assessment (LCA): The compilation and evaluation of the inputs, outputs and potential
environmental impacts of a product system throughout its life cycle. This definition is consistent with
the one in ISO 14044:2006.
Life cycle impact assessment (LCIA): The phase of LCA aimed at understanding and evaluating the
magnitude and significance of the potential environmental impacts for a product system throughout the
life cycle. This definition is consistent with the one in ISO 21930:2017.
Life cycle inventory (LCI): The phase of life cycle assessment involving the compilation and
qualification of inputs and outputs for a product throughout its life cycle. This definition is consistent
with the one in ISO 14044:2006.
Location-based accounting: A method to quantify scope 2 GHG emissions based on average energy
generation emission factors for defined locations, including local, subnational or national boundaries.
This definition is consistent with the one in the Scope 2 Standard of the GHG Protocol.
Market-based accounting: A method to quantify scope 2 GHG emissions based on GHG emissions
emitted by the generators from which the reporter contractually purchases electricity bundled with
instruments, or unbundled instruments on their own. This definition is consistent with the one in the
Scope 2 Standard of the GHG Protocol.
Material category: A group of construction products, construction elements or integrated technical
systems that can fulfill equivalent functions.
Post-consumer recycled content: Proportion, by mass, of recycled material generated by households
or by commercial, industrial and institutional facilities in their role as end users of the product that can
no longer be used for its intended purpose. This content includes returns of material from the
distribution chain. This definition is consistent with the one in ISO 14021:2016.
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Pre-consumer recycled content: Proportion, by mass, of recycled material diverted from the waste
stream during a manufacturing process. Excluded from this definition is reutilization of materials such
as rework, regrind or scrap generated in a process and capable of being reclaimed within the same
process that generated it. This definition is consistent with the one in ISO 14021:2016.
Primary data: Data determined by direct measurement, estimation or calculation based on specific
original source measurements for the specific system under investigation. This definition is based upon
the one in ISO 21930:2017.
Product category rules (PCRs): A set of specific rules, requirements and guidelines for developing
EPDs for one or more product categories. This definition is consistent with the one in ISO 14025:2006.
Product category rule committee (PCR committee): Group of interested parties tasked by the
program operator with drafting and finalizing the product category rules. This definition is consistent
with the one in ISO/TS 14027:2017.
Product type: A specific breakdown within a material category that adds specificity to what subgroup of
a material category is being referred to in a given context.
Program operator: The body or bodies that conduct an EPD program. A program operator can be a
company or group of companies, industrial sector or trade association, public authority or agency, or an
independent scientific body or other organization. Program operators are typically the organizations
that develop PCRs. This definition is based on the one in ISO 14025:2006.
Reference LCA: An LCA conducted prior to establishing or updating a PCR that aligns with the scope of
the PCR and is used as the basis for claims and determinations made within the PCR.
Scope 2 emissions: The indirect emissions from the generation of purchase or acquired electricity,
steam, heat or cooling consumed by the reporting entity.
Secondary data: Data indirectly determined through measurement, estimation or calculation and not
based on specific original source measurements. This can include data that is originally developed
using primary data sources, but is further aggregated to represent average processes or products. This
definition is based on the one in ISO 21930:2017.
Type III environmental product declaration (Type III EPD): An environmental claim that provides
quantified environmental data using predetermined parameters and, where relevant, additional
environmental information. This definition is consistent with the one in ISO 14025:2006.
Unit process: Smallest element considered in the LCI for which input and output data are quantified.
This definition is consistent with the one in ISO 14040:2006.
Upstream product category rule (upstream PCR): A PCR covering a system or process that is carried
out before the designated system or process associated with the given PCR. This definition is based on
the definition of the term "Upstream Process" found in ISO 21930:2017.
Waste: Substances or objects that the holder intends or is required to dispose of. This definition is
consistent with the one in ISO 14044:2006.
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List of Abbreviations
Abbreviation Full Description
ACLCA
American Center for Life Cycle Assessment
ANSI
American National Standards Institute
C02e
carbon dioxide equivalent
DOD
Department of Defense
DOE
Department of Energy
DOT-FHWA
Department of Transportation-Federal Highway Administration
DQA
data quality assessment
EAC
energy attribute certificate
EPA
Environmental Protection Agency
EPD
environmental product declaration
EPI
Energy Performance Indicator
FEMA
Federal Emergency Management Agency
FLCAC
Federal LCA Commons
GHG
greenhouse gas
GHGRP
Greenhouse Gas Reporting Program
GSA
General Services Administration
GWP
global warming potential
IDDI
Industrial Deep Decarbonization Initiative
IEC
International Electrotechnical Commission
IPCC
Intergovernmental Panel on Climate Change
ISO
International Organization for Standardization
LCA
life cycle assessment
LCI
life cycle inventory
LCIA
life cycle impact assessment
NTTAA
National Technology Transfer and Advancement Act
OMB
Office of Management and Budget
PCR
product category rule
REC
renewable energy certificate
SI
International System of Units
TS
Technical Specification
UNIDO
United Nations Industrial Development Organization
U.S.
United States of America
USDA
United States Department of Agriculture
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