Creating Environmental Product Declarations (EPDs) requires strict adherence to applicable standards and guidelines to ensure accuracy and credibility. However, several significant risks can arise during the process, each of which poses a threat to the overall integrity of the assessment.
In this article, we will explore four potential pitfalls, which can lead to a substantial amount of additional work and extend the project timeline beyond expectations.
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MASS BALANCE APPROACHā
Potential issue: In ECO EPDs (EPDs published by a program who is an ECO Platform member), the mass balance approach is not allowed anymore. This means that scrap content and renewable energy cannot be allocated to specific products based on manufaturers discretion. Previously, it was possible to create "green" product variations by allocating all of the renewable energy or scrap content to a specific product variation.
How to avoid: If it cannot be proven that only a specfic product variation uses the renewable energy or particlar raw material (for example, there's a separate product line or an electricity meter), this needs to be allocated between all products.
Where to find more information: Here is the ECO Platform Public Statement on the use of the Mass Balance Approach. Additonally, this rule is not incorporated to the product category rules (PCR) of the EPD programs.
How to avoid: If it cannot be proven that only a specfic product variation uses the renewable energy or particlar raw material (for example, there's a separate product line or an electricity meter), this needs to be allocated between all products.
Where to find more information: Here is the ECO Platform Public Statement on the use of the Mass Balance Approach. Additonally, this rule is not incorporated to the product category rules (PCR) of the EPD programs.
INCORRECT PRODUCT GROUPING
Potential issue: Sometimes, there are too many products to create a separate EPD for each one of them. It is allowed to group products but there are strict rules on how to do this and what kind of products can be grouped.
How to avoid: All program operators have clarified their rules on product grouping in their PCRs and c-PCRs. It is crucial to thoroughly read through the guidelines.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.
How to avoid: All program operators have clarified their rules on product grouping in their PCRs and c-PCRs. It is crucial to thoroughly read through the guidelines.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.
INCORRECT CO-PRODUCT ALLOCATION
Potential issue: Co-products often emerge alongside the primary product in the production process. It is essential to separate the impacts of these co-products from those of the main product to ensure accurate assessments. This can be achieved through methods such as mass allocation or economic allocation. Choosing the right methodology is crucial, as the results can vary significantly depending on the approach taken.
How to avoid: Co-product allocation rules are further clarified in the PCRs and c-PCRs.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.
Additonally, ECO Platform's LCA Calculation Rules and Specifications for EPDs have set further requirements for co-products used in cement and concrete.
How to avoid: Co-product allocation rules are further clarified in the PCRs and c-PCRs.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.
Additonally, ECO Platform's LCA Calculation Rules and Specifications for EPDs have set further requirements for co-products used in cement and concrete.
NOT ENOUGH PRODUCTION DATA
Potential issue: Generally, the data period for the Life-Cycle Analysis needs to be 12 months. Some EPD programs allow exceptions in the form of pre-EPDs or similar declarations. However, there isn't a set of common rules for this, so the precise requirements need to be checked.
How to avoid: All program operators have clarified whether shorter data periods are allowed in their PCRs and c-PCRs. It is crucial to thoroughly read through the guidelines.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.
How to avoid: All program operators have clarified whether shorter data periods are allowed in their PCRs and c-PCRs. It is crucial to thoroughly read through the guidelines.
Where to find more information: Program operators PCRs, c-PCRs, guidlines and general program instructions.