Normativity of PCRs within the NMD system

Stichting NMD manages a list of normative ‘(complementary) Product Category Rules’, or c-PCRs. A PCR sets out additional requirements beyond those in EN 15804, which must be followed when preparing an LCA for a specific product group.

There is some confusion in the market about how the normativity of PCRs within the NMD system should be interpreted, and what this means for the data in the NMD. This article explains how the entry into force of a new PCR affects the data in the National Environmental Database (NMD).

Table 1 below provides a schematic overview. It distinguishes between data already included in the NMD at the time the PCR becomes normative, and data submitted after the PCR has acquired normative status. The table also distinguishes between types of LCA studies: environmental declarations (modules A–D) and semi-finished products (modules A1–A3).

Footnotes

• * Allowed, but revision in line with the c-PCR is encouraged.
• ** Not allowed. Environmental declarations that do not conform to the normative PCR are not admitted into the NMD.
• *** Allowed if the data concerns a semi-finished product and if the deviation from the c-PCR does not affect the comparability and quality of the environmental profile. This is assessed during the verification process.

Because environmental data in the NMD has a validity period of five years, the entry into force of a new PCR does not affect data already included in the NMD. This data therefore remains permitted. A possible exception may occur if market actors with existing data in the NMD jointly decide to remove and resubmit their data in line with the new PCR.

For new data submissions to the NMD, the use of normative PCRs is always permitted. However, it is not allowed to submit an environmental declaration (covering modules A–D) to the NMD if the relevant normative PCR has not been applied. The recognised LCA verifier is responsible for ensuring this compliance.

In the context of public procurement, where a PCR may not yet have been designated, it remains possible to submit an LCA that is not in accordance with a PCR. However, such an LCA cannot be included in the NMD.

For semi-finished products, Stichting NMD allows inclusion in the process database under two conditions:

The title must explicitly state: “not in accordance with PCR – for public procurement”, to make it clear that these processes cannot be used in LCA studies for environmental declarations within the NMD. These basic processes may only be used in LCA studies for public procurement projects where a PCR has not yet been designated.

An alternative basic process that does comply with the PCR must also be available in the process database. This ensures that the use of the PCR remains possible and is actively promoted.

Important note

When verifying an environmental declaration for which a PCR is applicable, it is essential for the recognised LCA verifier to carefully check whether any NMD basic processes used in the study are marked as “not in accordance with PCR”. This designation is clearly indicated in the title of such processes.

Read all about Product Category Rules (PCRs)

PCR-cement in concrete products

It may occur that no PCRs are applicable when drafting an environmental declaration, while a normative PCR does exist for one of the raw materials used. This is currently the case for concrete products, where a normative NL-PCR exists for the component cement.

If there is no normative PCR for a product group, valid data on raw materials cannot be excluded. In the case of concrete, this means that environmental declarations for concrete may be generated using background data for cement that is not in accordance with the NL-cement-PCR. However, the background data for cement can also be generated in accordance with the PCR-cement. To ensure data comparability, it is crucial to have clarity on the application of PCRs. For this reason, foundation NMD sets the following requirement:

As long as no NL-concrete-PCR is available, the title must state whether or not the applied cement has been prepared in accordance with the NL-cement-PCR:

• [conforms PCR-cement] or
• [niet-conform PCR-cement]

In general, the rules are as follows:

• * Include in title: [conform PCR-X]
• ** Include in title: [non-conform PCR-X]

In these cases, foundation NMD promotes the development of a PCR for the overarching product group. In the example of concrete, a concrete-PCR is under development in which the use of cement-PCR will be made mandatory. Once the concrete-PCR comes into force, the application of the cement-PCR in concrete products will be unambiguous.