How to Write a PCR That Actually Gets Used
If an EPD is the product label, a Product Category Rule is the recipe card everyone agrees to follow. Get the recipe right and future LCAs and EPDs flow faster, reviewers align, and sales teams stop losing specs to “not comparable” footnotes. Here is the practical path teams ask for when they wonder how to write a PCR that will stand up in the market and actually help win work.
PCRs in plain English
A PCR is the rulebook of Monopoly: ignore it and the game falls apart. It defines what to measure, how to model a life cycle, and how results appear in an EPD so buyers can compare like for like. The goal is not poetry. The goal is repeatable, auditable decisions that different practitioners would apply the same way.
Do you really need to write one
Most products already fit under an existing PCR. Publishing under that saves calendar time and prevents lonely documents that no one uses. Write a new PCR only when the existing one clearly misrepresents your product class or blocks fair comparison. Teams asking how to write a PCR usually start with a scan of competitors’ EPDs to see which rulebook they follow.
Where PCRs live and who can lead
PCRs are hosted by EPD program operators that publish and maintain them. Common names in building products include EPD International, UL, IBU, BRE, and Smart EPD in the US. Any stakeholder can convene a PCR effort, but credibility rises when manufacturers, LCA practitioners, and independent reviewers co author the text and meeting notes stay public.
The skeleton every PCR needs
Expect a table of contents that reads like a careful blueprint. Scope and product category definition. Declared unit or functional unit. System boundary and modules. Data quality rules and allocation. Impact methods and indicators aligned with EN 15804 for construction products. Reporting format, verification requirements, and how updates happen. Keep wording unambiguous and test instructions with a sample model before publishing.
Declared unit, system boundary, and allocation
Pick a declared unit buyers actually understand, not an internal SKU. Write boundaries that match how the product is bought and installed. For allocation, set simple, defensible rules tied to physical relationships or market value and document exceptions with examples. When in doubt, show one numeric example so practitioners can mirror the math. If it confuses your own team, it will confuse everyone.
Data rules that make EPDs credible
State your preferred background databases and the minimum pedigree for primary data. Describe temporal coverage, geography, and technology representativeness, plus how to treat missing values. Spell out cut off logic and what happens when secondary data must stand in. Require practitioners to disclose key assumptions in the EPD so reviewers and buyers see the same picture.
Impact methods, scenarios, and comparability
Tie impact methods to widely accepted standards so your PCR does not drift. Include scenario guidance where performance depends on use or end of life. Give defaults and allow alternative scenarios when justified, then require transparency for any deviation. Comparability is a promise only when the same PCR governs both products, so teach readers exactly how to apply yours.
Review, consultation, and verification
Map the governance up front. Identify the technical committee, the independent reviewer role, and a public comment period with clear ground rules. A short pilot LCA before finalization exposes ambiguities faster than a dozen meetings. Verification requirements should be explicit so program operators and third party verifiers can apply them consistently without guesswork.
Maintenance, expiry, and version drift
PCRs expire, and that is healthy. Announce how revisions will be triggered and how long a grace window applies when a new version lands. EPDs based on an older PCR can remain valid until their own renewal, but teams should plan the next update against the newest rule set to avoid late surprises. Keep a change log that traces decisions and makes auditors’ lives easier.
The commercial upside of getting the PCR right
A crisp PCR shortens modeling time for every future EPD. Sales teams benefit when specifiers see apples to apples results without caveats. That means fewer slowdowns during bids and fewer debates about what the numbers actually mean. The time you save in data wrangling is time you can re invest in product improvements buyers notice.
A simple path from idea to published PCR
- Confirm an existing PCR does not fit and gather three to five real products that represent the category.
- Draft the skeleton, run a pilot LCA, and revise language where practitioners stumble.
- Convene a balanced review group, hold a transparent comment period, then verify the final with the chosen program operator. Publish with clear maintenance rules and a versioned template that others can follow without needing to email you for the missing pieces.
If you remember one thing, remember this. A PCR is a promise that two LCAs done by two teams will land in the same place. Write it so the next team can recieve it and get to work without calling for directions.
Frequently Asked Questions
What is the difference between a PCR and an EPD for construction products?
A PCR is the rule set for how to model and report impacts for a product category. An EPD is the verified label produced by applying that rule set to a specific product.
When should a manufacturer write a new PCR instead of using an existing one?
Only when the existing PCR leads to misleading results for the category or blocks fair comparison. If it fits, use it; if it does not, convene a multi‑stakeholder PCR effort and validate with a pilot LCA before publishing.
Do PCRs expiring make existing EPDs invalid immediately?
No. EPDs generally stay valid until their own renewal cycle. The next update must use a current PCR version unless a program operator provides a defined transition window.
Who should be on the PCR technical committee?
Manufacturers from the category, experienced LCA practitioners, at least one independent reviewer, and a representative from the intended program operator to align on verification needs.
What program operators are common for building products?
EPD International, UL, IBU, BRE, and Smart EPD are frequently used. The best choice depends on market, customer expectations, and how you plan to distribute EPDs.
About the Author
Eric works at the intersection of sustainability, regulation, and business strategy, helping manufacturers navigate the evolving landscape of EPDs and LCAs. Having spoken with hundreds of teams across North America, brings a deep understanding of what drives ROI, what regulators are asking for, and how companies can stay ahead with smart, scalable approaches to environmental reporting.
