Program Operators and Product Category Rules

Environmental Product Declarations don't exist in isolation—they operate within structured programs managed by organizations called Program Operators. These programs define rules through Product Category Rules (PCRs) that ensure EPDs are credible and comparable.

What is a Program Operator?

A Program Operator is an organization that manages an EPD program according to ISO 14025. They serve as the governing body for EPD development, verification, and publication.

Program Operator Responsibilities

Major Global Program Operators

Several program operators operate internationally:

EPD International (The International EPD System)

• Headquarters: Stockholm, Sweden
• Coverage: Global, all product categories
• EPDs registered: 5,000+
• Website: environdec.com

UL Solutions (formerly UL Environment)

• Headquarters: United States
• Coverage: North America, global
• Specialties: Building products, electronics
• Website: ul.com/epd

IBU (Institut Bauen und Umwelt)

• Headquarters: Berlin, Germany
• Coverage: Europe, construction focus
• EPDs registered: 3,000+
• Website: ibu-epd.com

NSF International

• Headquarters: United States
• Coverage: Global, diverse categories
• Website: nsf.org

Sector-Specific Program Operators

Some program operators focus on specific industries:

Construction and Building Materials:

• ASTM International (US construction products)
• BRE Global (UK building materials)
• Sustainable Minds (US building products)

Other Sectors:

• PEP Ecopassport (electrical/electronic equipment)
• Declare (building products, Living Building Challenge)

Understanding Product Category Rules (PCRs)

Product Category Rules are the detailed instructions that ensure EPDs for similar products are developed consistently and can be compared.

What PCRs Define

A PCR specifies requirements in several areas:

Functional unit: How to express the product's function for comparison.

Example from a flooring PCR: "1 m² of installed floor covering providing its stated function for a reference service life of 50 years."

System boundary: Which processes must be included.

Example: "The system boundary shall include raw material extraction (A1), transport to manufacturer (A2), and manufacturing (A3) as mandatory modules. Use stage and end-of-life are optional."

Allocation rules: How to handle multi-output processes.

Example: "For sawmill products, allocation shall be based on mass. For recycled inputs, the cut-off approach shall be applied."

Data quality requirements: Minimum standards for data sources.

Example: "Primary data less than 5 years old shall be used for all foreground processes. Background data shall be from ecoinvent 3.x or equivalent."

Impact categories: Which environmental indicators to report.

Example: "The following impact categories shall be reported: GWP, ODP, AP, EP, POCP, ADPE, ADPF, and water use."

Reporting format: How results must be presented.

PCR Structure (Example)

A typical PCR includes these sections:

1. Scope and definition - Products covered, geographic applicability
2. Product category description - Technical definitions
3. Goal and scope requirements - Functional unit, system boundary, cut-offs
4. Life cycle inventory requirements - Data collection, allocation
5. Life cycle impact assessment requirements - Methods, categories
6. Content of the EPD - Mandatory and optional information
7. Validity and updates - PCR lifespan, revision procedures

PCR Development Process

Creating a new PCR involves structured stakeholder engagement:

Step 1: Initiation

A company, industry association, or program operator identifies the need for a PCR. This typically involves:

• Market demand assessment
• Stakeholder interest gathering
• Work plan development

Step 2: PCR Committee Formation

A diverse committee is assembled including:

• Industry representatives (manufacturers)
• LCA experts
• NGOs or civil society
• Academia
• Downstream users

Step 3: Draft Development

The committee develops the PCR draft:

• Review existing standards and PCRs
• Define scope and functional unit
• Establish methodological rules
• Create reporting templates

Step 4: Open Consultation

Draft PCR is published for public comment:

• Minimum consultation period (typically 30-60 days)
• All stakeholders can submit comments
• Comments must be addressed with rationale

Step 5: Finalization and Approval

After addressing comments:

• Final PCR reviewed by program operator
• Technical committee approval
• Publication and registration

Step 6: Maintenance

PCRs require ongoing maintenance:

• Periodic review (typically every 3-5 years)
• Amendments for new standards or methods
• Stakeholder feedback incorporation

PCR Harmonization Efforts

Different program operators historically developed separate PCRs for the same products, limiting comparability. Several initiatives address this:

EN 15804 (Construction Products)

The European standard EN 15804 provides core rules for construction product EPDs, which national program operators then supplement with product-specific rules. This creates a harmonized baseline across Europe.

c-PCR (Complementary PCR)

EPD International uses a c-PCR structure where:

• A general program instruction provides baseline rules
• Product-specific c-PCRs add category details
• This creates consistency across product types

PCR Guidance Documents

ISO and regional bodies publish guidance:

• ISO 14027 provides PCR development principles
• GEDnet (Global EPD Network) promotes harmonization
• SCS Global Services facilitates multi-program PCRs

Finding Existing PCRs

Before developing a new PCR, search for existing ones:

Program Operator Libraries

Most operators maintain searchable PCR databases:

• EPD International: environdec.com/pcr-library
• UL Solutions: ul.com/services/pcr-finder
• IBU: ibu-epd.com/product-category-rules

Cross-Program Search

EPD Hub (epd-hub.com) aggregates PCRs from multiple operators, making cross-program searching easier.

Key Questions When Selecting a PCR

1. Does it cover my specific product type?
2. Is it current (not expired)?
3. Is it recognized by my target market/customers?
4. Are the system boundary requirements achievable?
5. Do I have access to required data?

When No PCR Exists

If no suitable PCR exists, you have options:

Option 1: Develop a new PCR

• Time-intensive but creates precedent
• Requires stakeholder coordination
• Positions you as industry leader

Option 2: Extend existing PCR

• Work with program operator to expand scope
• Faster than new development
• Maintains consistency

Option 3: Use general rules

• Some operators allow EPDs under general program rules
• May have limited comparability
• Useful for novel products

Mutual Recognition Agreements

Some program operators have agreements recognizing each other's EPDs:

• GEDnet members accept EPDs from partner programs
• Specific bilateral agreements between operators
• Regional harmonization (e.g., within Europe under EN 15804)

This means an EPD registered with one operator may be recognized by another without full re-verification.

Key Takeaways

1. Program operators manage EPD programs and ensure quality
2. PCRs provide specific rules for product categories enabling comparison
3. Multiple program operators exist—choose based on market recognition and PCR availability
4. PCR development involves structured stakeholder engagement
5. Check for existing PCRs before developing new ones
6. Harmonization efforts are increasing cross-program comparability

What's Next?

With understanding of the EPD ecosystem, the next lesson walks through the complete process of creating and publishing an EPD for your product.

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Further Reading

• ISO 14027:2017 Environmental labels and declarations — Product category rules
• EN 15804:2012+A2:2019 Sustainability of construction works
• GEDnet - Global EPD Network