State of PCR Methods 2026

A Machine-Readable Inventory of Product Category Rules

PCRbase · June 2026 · nickgogerty.github.io/pcrbase

Executive Summary

• 290 Product Category Rules from 7 program operators are now machine-readable — the first structured, open inventory of PCRs ever compiled. Across 302 versions, 4,409 normative requirements have been extracted, normalised, and mapped to the COMET carbon ontology.
• The EPD industry faces an expiry cliff. 92 PCR versions (30% of the tracked corpus) have already expired, and a further 59 versions expire in 2026 alone. Practitioners relying on outdated rules risk non-compliant EPD declarations without a structured alert system.
• Method fragmentation is real but concentrated. 78% of PCRs follow ISO 14067 (EnvironDec-dominated), 14% follow EN 15804, and 8% follow EU PEF — yet the three methods share only partial clause overlap, creating silent incompatibilities for cross-program comparisons.

1. The PCR Landscape

Coverage at a glance

The seven operators in the current corpus — EnvironDec (IVL), EPD Norge, EU EF/PEFCR, US EPD, BRE, EPD Hub, IBU — collectively represent an estimated 18–20% of the global PCR universe (~1,500–1,700 PCRs across 26+ known operators). The remaining operators are either gated (UL SPOT, KEITI, JEMAI) or have not yet been harvested (INIES, PEP ecopassport, EPD Italy, Australasia).

Operator breakdown

EnvironDec alone accounts for 78% of the inventoried corpus, reflecting both its scale and the relative openness of its data infrastructure. 54 EnvironDec entries are metadata-only (c-PCRs with no standalone PDF), a structural feature of the category-PCR / sub-PCR architecture.

2. Method Fragmentation

Three normative frameworks govern how EPD carbon footprints are calculated:

These frameworks are not equivalent. PCRbase's clause-level analysis across 65 normalised requirement keys finds that:

• System boundary (modules A1–D) is declared differently across all three — EN 15804 mandates explicit module-by-module declaration; ISO 14067 allows more flexible scoping; PEF mandates all life-cycle stages.
• Allocation rules diverge sharply: EN 15804+A2 mandates the Circular Footprint Formula (CFF) for recycled content; ISO 14067 PCRs vary between physical, economic, and system-expansion approaches.
• LCIA indicator sets are largely disjoint: EN 15804+A2 requires 16 EF impact categories; ISO 14067 PCRs typically require only GWP100; PEF requires the full EF 3.1 set (16 categories) but with different characterisation factors.

Cross-program EPD comparisons — increasingly demanded by CBAM, ISO 14064-3 verifiers, and EU Green Deal procurement — are currently impeded by this fragmentation. PCRbase's ontology mapping provides the first machine-readable bridge.

3. The Expiry Cliff

Of the 302 PCR versions in the corpus, 221 carry an explicit validity date. The distribution reveals a structural problem:

59 PCR versions expire in 2026 — the single largest annual cohort. If manufacturers and consultancies are unaware of expiry, EPDs declared against superseded rules remain technically non-compliant. Most EPD program portals do not send automated alerts; practitioners must check manually.

PCRbase addresses this directly: the version diff monitor detects expiry events and PCR updates in the harvested corpus daily, delivering alerts when changes are detected.

4. Data Quality Findings

Extraction confidence (LLM + span verification)

Extraction was performed using Claude Haiku 4.5 with a verbatim span-verification gate: each extracted value must be locatable as a substring in the source PDF. Results across 4,409 requirements:

• 3,884 requirements (88%) passed span verification — the extracted value is directly attributable to the source document.
• 12% of requirements are flagged as unverified, typically due to OCR artefacts in scanned PDFs or implicit values not explicitly stated in text.

COMET mapping completeness

All 65 normalised clause vocabulary keys now have a COMET mapping:

The 50 extended mappings constitute a structured evidence base for upstream PRs to the COMET ontology — each proposing a concrete new class or property with rationale and occurrence count.

5. What This Means for EPD Practitioners

1. Stop treating PCRs as PDFs. 4,409 requirements across 290 PCRs can now be queried as structured data. Practitioners building EPD software, verifier tools, or CBAM declarations no longer need to manually cross-reference PDFs to find applicable rules.

2. Build expiry monitoring into your workflow. 42% of the PCR versions in the open corpus are already expired. Any automated EPD pipeline should check valid_until against today's date before applying a PCR's requirements. PCRbase provides this check as a free API endpoint.

3. Cross-program comparison requires an ontology bridge. The three major methods (ISO 14067 / EN 15804 / PEF) are structurally incompatible at the clause level without a shared semantic layer. The COMET ontology — with PCRbase as its primary PCR evidence base — is the emerging standard for this bridge.

About PCRbase

PCRbase is an open-source project maintaining a versioned, machine-readable inventory of Product Category Rules, with requirements extracted and mapped to the COMET carbon ontology. The pipeline uses DuckDB as a system-of-record, Claude Haiku for LLM-assisted extraction with span-verification gates, and generates RDF/JSON-LD aligned to COMET.

Data access: nickgogerty.github.io/pcrbase · GitHub: nickgogerty/pcrbase

Contact: nickgogerty@gmail.com · Data: CC BY 4.0 · Code: MIT