PCR Guidance Review for the Sustainable Apparel Coalition
PRé was commissioned to review the internal PCR Guidance documents for the Sustainable Apparel Coalition. This coalition spans about one-third of the apparel (clothing and shoes) sector. Their aim is to create a Higgs index for all apparel, reflecting the environmental impact
Potentially, this initiative will turn into a label. As part of this index, Product Category Rules (PCRs) are needed. PRé reviewed the document describing the rules and guidelines for developing PCRs. The project was executed by Mark Goedkoop (PRé founder), Vee Subramanian (PRé North America senior consultant and author of the U.S.-initiated Global PCR Guidance Initiative), as well as Koichi Shobotake (TCO2 president, PRé’s Japanese partner). Shobotake plays a very important role in Japan’s footprinting development. With this team, we had a truly global base.
The review of a PCR guidance document is quite different from the review of an LCA, or even a PCR itself. The first step was to develop a consensus on the criteria, against which to review. For this we studied the ISO 14025 standard. From there we developed the criteria. We think the questions are useful for anyone developing PCR guidance:
Program and consultation process | Scope and objectives
First, we considered the program and consultation process scope and objective, as well as the parameters of its intended audience:
Is the involvement of interested parties well defined?
Is the consultation process well established for the development of PCRs?
Is the consultation process well established for developing the rules needed to produce a declaration?
Defining product categories and data management
Also considered was the procedure for defining product categories and data management:
Is the procedure for defining product categories and data management well described?
Is there a well-established procedure for maintenance and updating provisions of the PCR?
From a maintenance standpoint, the particulars of verification, funding, and fees were also taken into account:
Is the procedure for independent verification well defined, including the competence of verifiers, and the competence of the PCR review panel?
Are the resources, including funding for the program management well defined; are fees, if any described?
What is the procedure for reviewing the program instructions?
And finally, incentives were considered, to ensure motivation remained high:
Does the PCR guidance give sufficient incentive to achieve harmonization (this is a “should” and is thus not a strict requirement)?
Does the PCR guidance give sufficient incentive to ensure that the PCRs will satisfy the required level of clarity and consistency for:
i) A proper product category definition
ii) A proper functional unit, as defined in ISO 14040
iii) Well-defined inventory procedures
iv) Well-defined impact assessment
v) Clear description of what needs to be declared, and how this needs to be presented, and how the format should be used
Of course we also checked for more general things like readability, consistency, and comprehension. We developed quite a long list of recommendations and presented this to the coalition. Recently these comments and the public stakeholder consultation led to a final version of the guidance document.
If you want to know more about this topic, please feel free to contact me, your questions and feedback are very welcome!