Who Writes PCRs and How They Happen
A Product Category Rule (PCR) is the referee’s whistle in the EPD game: it sets the limits, spells out the scoring system, and keeps everyone playing fair. Yet many manufacturers still wonder who drafts these rules, how long it takes, and whether they have a seat at the table. Consider this your sideline pass.
PCRs: The Rulebook Behind Every EPD
A PCR translates broad standards like ISO 14025 and EN 15804 into sport-specific playbooks. Skip it and your LCA numbers will not make it onto the scoreboard.
Who Puts Pen to Paper
Program operators—think IBU, the International EPD System, or ASTM—convene a committee of manufacturers, trade bodies, academics, and LCA pros. They steer the process and ensure the final text checks every ISO box.
The Five-Step Workflow in Plain English
- Initiation: a moderator is appointed and scope announced.
- Preparation: the draft PCR is written with reference data.
- Open consultation: anyone can comment online.
- Approval: an expert panel signs off.
- Publication: the operator posts the final PDF and starts the clock toward the next revision (International EPD System, 2025).
Timeline Reality Check
Developing a fresh PCR takes five to twelve months, mostly because of public consultation and ballot cycles (Sal-Tech, 2024). Operators that update instead of create can cut that in half, as seen with IBU’s April 2024 Part A refresh that went live after a six-month transition (IBU, 2024).
Your Role as Manufacturer
You are not required to draft the document, but smart suppliers join the committee early. Sharing plant data or practical use-phase insights can head off unrealistic assumptions that might inflate your impacts later.
When No PCR Exists
A trade association, a coalition of competitors, or even a single company can petition an operator to start one. Expect to supply market definitions, expected functional units, and sample LCAs. Budget staff time rather than cash; operators cover administration but lean on you for technical grit.
What If Two PCRs Overlap
Pick the one recognized in your target market or by the tendering authority. When in doubt, choose the PCR that aligns with EN 15804 +A2 because most construction credits point there. If scopes genuinely clash, operators can harmonize or merge during the next revision cycle, so flag the issue instead of cherry-picking.
Bottom Line for Busy Teams
A solid PCR makes every subsequent EPD faster, cheaper, and less stressful. Getting involved once can spare you serial headaches for the next five years until the rulebook renews.
Frequently Asked Questions
Do manufacturers have to write a new PCR themselves?
No. Program operators lead the drafting. Manufacturers typically join the committee to supply data and sanity-check assumptions.
How long before a new PCR is ready for use?
Five to twelve months is typical because of stakeholder review cycles (Sal-Tech, 2024).
Can I publish an EPD without a PCR?
Not under ISO 14025. Program operators will not register an EPD unless it strictly follows a valid PCR.
What happens if two PCRs cover my product?
Choose the one cited by buyers or regulations in your biggest market. If overlap causes confusion, raise it with the operator so the next revision can bridge the gap.
How often are PCRs updated?
Most operators mandate revision every five years; IBU’s 2024 update to its core rules is a recent example (IBU, 2024).
Will my existing EPD expire when a PCR is revised?
Only if the operator sets a sunset date, often eighteen to twenty-four months after the new version releases. Check the notice that comes with the update.
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
