Embodied carbon reporting in Declare was introduced as a pilot program in 2019 and remains in pilot phase until further announcement. The following guidelines are for review and reference only. For manufacturers interested in learning more and disclosing their embodied carbon impacts when the program opens following the conclusion of the pilot phase, please contact the Declare Support team with this information at firstname.lastname@example.org.
Embodied Carbon Reporting
Embodied carbon is now an optional reporting field for manufacturers in the Declare program. Embodied carbon and interpretations of environmental impact with this metric are meant to complement the ingredient transparency information that forms the basis of Declare. Manufacturers that do not have embodied carbon information to report, or that have chosen not to disclose this information, are not penalized with respect to declaration status or overall LBC compliance.
Embodied carbon data for building products in Declare come from publicly available Type III facility-specific or product-specific cradle-to-grave, or cradle-to-gate with options (which must include end-of-life, C1-C4) Environmental Product Declarations (EPDs) completed to a relevant Product Category Rule (PCR) that are published by a fabricator, product manufacturer or other declaration holders, or by ISO 14025 program operators that have completed the third-party verification and registration of the EPD, as defined in ISO 14025, ISO 14044, and ISO 21930 and/or EN 15804. The American Center for Life Cycle Assessment (ACLCA) maintains a list of active global ISO 14025 program operators: https://aclca.org/pcr/program-operators/
EPDs that are completed to cradle-to-gate scope (Modules A1-A3) only are considered non-compliant to Declare requirements for embodied carbon reporting at this time.
The Declare label reports the declared unit and the global warming potential (GWP) (expressed in units of kg CO2-eq) associated with the A1-A3 product stage module. Declared units reported on Declare labels do not take into account performance criteria or product functional equivalence considerations for the referenced baseline. The declared unit is obtained from the EPD and should be one of the following:
- an item, an assemblage of items, for example, 1 window (dimensions of items shall be specified);
- mass (kg or metric tonne), for example, 1000 kg or 1 ton of cement;
- length (m), for example, 1 m of pipe, 1 m of a beam (dimensions of elements shall be specified);
- area (square meter/sq m), for example, 1 sq m of wall elements, 1 sq m of roof elements (dimensions of elements shall be specified);
- volume (cubic meter/cu m), for example, 1 cu m of timber, 1 cu m of ready-mixed concrete.
If a different unit is declared, the EPD should also provide information on how to convert this unit into one of the above accepted formats; the converted unit will be displayed on the Declare label.
Project teams and other Declare label users should consult the EPD (linked to on the Declare database) for functional units (when available and reported) as the preferred basis for product EPD comparisons. Without options to report product function information on a Declare label, users are encouraged to project teams should consult other programs and materials for further information and guidance on making comparisons of products with similar functional units with cradle-to-grave impact information.
[ISO 21930, section 7.1.3]: “When the precise function of the product or scenarios at the construction works level is not stated, or is unknown, a declared unit may be used instead of the functional unit. The declared unit provides a reference by which product, material and energy flows (input and output data) of the information module of a construction product’s LCA results and any other information are normalized to produce data expressed on a common basis.”
For Declare products with multiple final assembly locations, an asterisk denotes the locations for which the embodied carbon data (that meet the above reporting requirements for Declare) is valid.
Additional information that will be listed on the Declare database in the product description include:
- Impact assessment tool/method used
- Link to the published EPD (Link will direct to the EC3 database if the EPD has been uploaded there)
Declare Embodied Carbon Indicator Guide
A graphic indicator will appear next to the product’s global warming potential (GWP) to identify its cradle-to-gate embodied carbon impact relative to the product type category upper limit as proposed by the Embodied Carbon in Construction Calculator, an open-source EPD database and building planner tool that enables a performance-based approach to evaluating embodied carbon reductions in design, procurement, and construction. The EC3 tool holds a growing repository of product EPDs, and Building Transparency and the Carbon Leadership Forum have proposed methodologies to account for uncertainty in data quality and facilitate comparability of EPD data in accordance with ISO and EN standards. If a product EPD is published in the EC3 database, ILFI will include this link to the EPD on the Declare database to facilitate EC3’s product-type comparisons, where converted units and relevant uncertainty factors in the data can be viewed in context and alongside other EPDs in the same product-type category.
= above product type baseline
= below product type baseline
= within product type baseline range
= no product type baseline calculated or available
ILFI will use the product type baseline that has been calculated at the time of the Declare label application review. If a manufacturer renews the Declare label for its product, ILFI will reconfirm the continued validity of all associated EPD and PCR submissions and reevaluate this performance to the EC3-determined product type baseline at that time.
If the product EPD or its product category have not yet been included in EC3 and its comparison methodologies, manufacturers may request to report the GWP and declared unit in the product EPD, and the product Declare label will have a grey bar as its indicator, as no product type baseline is available. Additionally, cradle-to-gate EPDs with optional modules will also have a grey bar as the indicator, as this type of EPD is not suitable for comparison.
ILFI will review and approve additional baseline calculations and benchmarks on an ongoing basis. Questions or requests for consideration of additional qualifying databases and embodied carbon benchmarks may be submitted to email@example.com for consideration. Refer to the LBC 4.0 Energy Petal Handbook in the ILFI Member Dashboard for the latest guidance and reference to approved calculators and product type baselines.
Product Type Categories
Products are considered to be in the same product type category for comparison purposes if their third-party verified EPDs follow the same Product Category Rule (PCR) that conforms to the requirements of comparability of ISO 21930 and ISO 14025.
[ISO 21930, section 6.3]: “The product group covered by a sub-category PCR shall be described unambiguously. The definition may consider product functionality (e.g. conveyance of materials through pipes), typical production processes (e.g. mining or oil refinery) or applications (e.g. for use in cold climates). If there is potential ambiguity in the product sub-category, the description shall also state which products are not covered by the sub-category PCR.”
Declare labels will reference product type baselines (defined as the 80% upper limit GWP of the material category) and material categories of the EC3 database when available and applicable. As of January 2021, the product categories represented in EC3 include:
- Structure: Concrete, Steel, Wood
- Enclosure: Aluminum, Glass Panes, Insulation, Gypsum Wall Board
- Finishes: Carpet, Ceiling Panels
Additional Product Type Baselines Not Currently Represented
For product types or functions where the EC3 calculator has not determined an embodied carbon baseline, industry representatives and project teams can submit a proposed product baseline, defined by one of the following:
- ILFI-approved baseline tool or methodology
- Proposed by the project team or industry representative, based on a review of comparable products in the same material category and represent common supply chain and manufacturing data, and declared unit for the product type.* This does not include industry-wide EPDs or other broad categorical studies of manufacturing impact.
*Note that additional product baselines must be submitted to ILFI for approval, and must disclose the baseline methodology, data source(s), data uncertainty and statistical significance of the study.
ILFI will periodically review the baselines referenced within Declare labels and determine whether there more stringent product baselines are required to continue pushing various building product industries to work toward mitigating product embodied carbon.
Embodied Carbon Notes for Manufacturers
For Declare manufacturers: All EPDs should meet the protocols for scope, preparation and external third-party verification as outlined in ISO 14025 or ISO 21930, and EN 15804. All EPDs referenced should be as current as possible, and at a minimum shall not expire for one year (i.e. before the expiration date of the Declare label). With respect to data quality, underlying LCA data must be sourced from within the last ten years prior to the publishing of the EPD, and utilize specific data from the country or countries/regions of actual production where possible. Manufacturers should continue to move toward the use of supply chain-specific upstream data to inform LCA and EPD development. ILFI continues to contribute to discussions of best practices in data quality measurement and reporting.
For LPC manufacturers: Manufacturers that have completed a third-party verified LCA through the Living Product Challenge and either do or do not have a third-party verified EPD will be able to include embodied carbon on the product’s Declare label, but without a baseline reference indicator because the data are calculated under different parameters and should not be compared with EPD-reported impact data. Products that do have both LCA and EPD data will have their EPD figures reported on both Declare and LPC labels for data consistency if the product manufacturer requests to include environmental impact data on both program label disclosures.
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