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The New Direction: Environmental Product Declarations

A new Window Product Category Rule was recently created through the joint effort of the American Architectural Manufacturers Association, Insulating Glass Manufacturers Alliance, Glass Association of North America and Window and Door Manufacturers Association. This PCR is the guide for developing an Environmental Product Declaration, which is the manufacturer’s detailed statement of the environmental impact of its product.

The start has been slow and EPDs are perceived as a valuable marketing tool at this point. But, with the rapid growth of the green building market, EPDs will become essential to the ability to thrive in this industry as they are likely to become a future code requirement.

The Window PCR defines data to be used in performing a Life Cycle Assessment for window products, including how the information is to be obtained and reported. The LCA is an analysis of the data identified in the PCR used to determine the cradle-to-gate environmental impact of a product.

The LCA uses scientifically accepted methods to analyze the impact of each product life stage, from the raw material production to packaging and distribution, all the way through disposal, reuse or recyclability of the product. Then, the EPD reports the results of the LCA for a given product and is verified by an independent third party. Validation of the EPD confirms that the data used to perform the LCA was collected in accordance with the technical PCR requirements.

Primary Data

In order to meet the requirements for an EPD, at least 95 percent of all mass and energy used in the system must be accounted for, as well as all toxic materials as defined by the Environmental Protection Agency. The Window PCR requires that primary data be used in developing the analysis whenever possible. (Primary data is the information collected by the manufacturer from facilities and processes directly related to or under the control of the manufacturer. Note: it’s important to verify the accuracy of information obtained by these outside sources.)

Primary data includes location of manufacture, quantity and source of materials and energy used to manufacture the product, and the waste produced. If primary data is unavailable, then secondary or tertiary data may be used relating to facilities and processes outside of the control of the company.

Presenting the Information

The Window PCR identifies categories of data to be included in an EPD in the form of a Table of Results substantially similar to the format expressly described in the PCR. The Table breaks out data to focus on specific aspects of the environmental impact. Even the installation of the product must be considered when developing the EPD, as the analysis must encompass all materials required for installation with the exception of insect screens.

Also, the Window PCR requires identifying information such as the name of product, use of the product, a photo of product, and the name/logo of the manufacturer. The EPD must also contain information pertaining to the development of the EPD, including the specification the product meets, the name of the PCR, date and expiration of EPD, third-party validation, and contact info for the validator. Also note that the EPD must provide a disclaimer that states the EPD and PCR process is informational only and does not warranty performance.

Make every effort to confirm the underlying data is accurate. When relying on data from sources outside of the company—information from distributors or component suppliers, etc.—take extra care to ensure the information used to generate the LCA is reliable.

In the potential that the representations made in the EPD could be questioned, it’s crucial to be able to point directly to the collected data and confirm the information is reliable and up-to-date. In fact, the Window PCR requires that all foreground data must be no more than three years old with limited exceptions.

With a goal of transparency, any company developing an EPD must bear in mind that, with transparency comes exposure to challenges. The Window PCR states the requirements, but properly meeting those requirements depends heavily upon collecting quality data.

Ultimately, the EPD is only as reliable as the data used to generate it. An attack on the underlying data could undercut the benefits of having an EPD in the first place if the stated environmental impact is vulnerable to a claim of misrepresentation. In any event, the first step in developing a thorough and consistent EPD is to understand the technical requirements of the window PCR.


Melanie Sherer PR Gary Law

Melanie Scherer

Melanie Scherer is an attorney with The Gary Law Group, a law firm based in Portland that focuses on legal issues facing manufacturers of windows and doors. Contact her at 503/620-6615 or