When No PCR Exists: How To Forge One
Running into a product with no Product Category Rule feels like opening Monopoly and finding the rulebook missing. You *could* play by house rules, but the bank will call foul. Below is the fast-track map manufacturers use to write the missing rulebook—and get back to winning bids—without drowning in redlines.
A blank PCR is a bid-killer
Specs written around Environmental Product Declarations expect apples-to-apples comparison. Without a PCR, your LCA has no yardstick, so building-rating schemes from LEED to DGNB flag it as non-comparable. The result: architects skip over your product in minutes, no matter how green it is.
Stakeholders you need in the room
A PCR is an industry consensus document, not a lone-wolf manifesto. Bring in at least one trade association, two or three peer manufacturers, an LCA practitioner, and the chosen program operator. That mix checks the three Cs: credibility, comparability, and cost-share.
The five-step playbook
1. Gap scan. Confirm no overlapping PCRs exist in databases like ECO Portal or INIES. A quick mis-match check now saves three months later. 2. Charter the working group. Formal invitations, conflict-of-interest statements, and selection of a lead author. The stakeholder group decide the scope early. 3. Draft to EN 15804+A2 and ISO 14025. Use the latest clauses. A draft that ignores the EPA’s 2024 data quality flags will stall at review (EPA, 2024). 4. Public comment & peer review. Minimum 30 days on the operator’s site, plus direct outreach to academics and NGOs. 5. Final approval and publication. The operator issues an official PCR ID. Celebration optional, but recommended.
Timeline and budget realities
IBU’s photovoltaic PCR project launched in June 2024 with a 24-month window—fairly typical for complex products (IBU & Fraunhofer ISE, 2024). Leaner categories like metal hardware land in 9–12 months. Direct fees to the operator tend to stay below USD 20 000, yet the biggest line item is staff time for consensus calls. Reliable cross-sector averages are scarce; plan for 120–150 team hours unless someone steers the calendar full-time.
What makes a good lead facilitator
Pick a firm that couples seasoned LCA chops with ruthless project management. Look for these tells:
- A documented PCR template library aligned to EN 15804 and ISO/DIS 14025 (2025 draft).
- A steering plan that locks weekly deliverables, not vague milestones.
- A data-collection engine that lets each plant upload inventories in hours, not weeks.
- A track record of shepherding at least two PCRs from draft to publication in the last three years. Data come fast and messy, experiance matters.
Wrap: turn the gap into advantage
Yes, drafting a PCR is heavier than using an existing one, but ownership pays back. Early movers often shape functional unit definitions that spotlight their strengths; later entrants must follow. Nail the process once, and every follow-on EPD drops in price and effort. The protocol from Stichting NMD even shows how new PCRs become normative inside national databases within a year (NMD, 2025). Missing rulebook? Write it—before your competitor does.
Frequently Asked Questions
How long does it usually take from PCR kickoff meeting to publication?
Complex categories (e.g., PV modules) run about 24 months, while simpler hardware can clear review in 9–12 months (IBU & Fraunhofer ISE, 2024).
Who pays the program operator’s fees for a new PCR?
Costs are normally split among the working-group manufacturers or their trade body. Operator charges rarely exceed USD 20 000, but staff time often doubles that figure.
Can we draft a PCR without a trade association?
Yes, but you’ll need at least two peer manufacturers to satisfy most program operators’ consensus rules (ISO 14025, 2025 draft).
What happens if ISO/DIS 14025 publishes after our PCR is approved?
Program operators usually grant a transition period—often two years—to update wording and indicators, so your fresh PCR remains valid while you revise.
Will the EPA’s 2024 PCR criteria affect projects outside the U.S.?
Indirectly, yes. Operators worldwide are aligning on its data-quality checkpoints to keep U.S. market access options open (EPA, 2024).
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
