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A Legal Perspective on Life Cycle Assessment

Windows are often treated more like raw materials than what they actually are: an assembly of parts and pieces operating in a designed system. This reality has become more apparent as the overall fenestration industry addresses Product Category Rules (PCR). These rules are ultimately part of a Life Cycle Assessment (LCA), which is an overall representation of a product’s impact on the environment, from the cradle to the gate/grave.

Knowing how these items work for particular products can guide your own compliance and help you evaluate your supply chain. And as these items gain increasing force of law and grow as contractual requirements, that knowledge may soon prove crucial to understanding where and how environmental representations shield or harm a trade’s work.

The recent window PCR gives us a good opportunity to look at the rules themselves and the accompanying risk points. In September 2015, the joint effort of the American Architectural Manufacturers Association,, the Glass Association of North America,, the Insulating Glass Manufacturers Alliance,, the Window and Door Manufacturers Association,, and other industry participants, resulted in the development of a PCR for windows installed in residential, curtain wall and ribbon wall installations. This rule was the culmination of years of collaborative effort among industry leaders. And while market-driven forces are a large motivation behind the current push, these efforts are gaining the force of law as more jurisdictions adopt code requirements focusing on a project’s environmental impact.

Generally, a PCR sets out a means for manufacturers to develop Environmental Product Declarations (EPD). EPDs are intended to be compared, equally, when a buyer is weighing the environmental impact of their purchase.

For windows, the PCR requires information relating to fabrication of the system and incorporated components, as well as the items used in installation. This data is gathered, reviewed and presented in a uniform structure set out by the PCR. This ultimate presentation is the EPD.

If all manufacturers abide by the layout and required reporting, a consumer can theoretically pick up different products’ EPDs and have a consistent presentation of environmental factors potentially weighing on their purchasing decision. And, while the EPDs themselves are informational only, requiring a disclaimer for any warranty of performance, the weight of these disclosures on future sourcing decisions cannot be ignored.

For many products, the PCR process requires a manufacturer validate that upstream suppliers are making an accurate and properly assessed EPD. The window PCR is no different. Window manufacturers must rely on data from their suppliers for hardware, weather seals and glass, many of whom likely have their own PCRs. In addition, they must specify installation expectations and incorporate EPDs from those materials as well. A failure in any part of the supplier network or installation recommendations has the potential to undermine a window manufacturer’s EPD.

As you might imagine, data transparency is an important requirement of the PCR/EPD process. The data on which an EPD is based must be verifiable and current. The window PCR requires underlying data be no less than three years old. That means manufacturers and those who rely on EPDs must ensure their PCR process validates the accuracy and timeliness of their primary data and their suppliers. This can be a tall order.

While there are challenges, the window PCR process is a step toward finding a common ground from which consumers and users can view environmental performance. Compliance can present a complex picture for those making, selling and using window products, but the PCR requirements are critical to an effective and reliable EPD. That compliance, however, requires careful evaluation of the process, data and documentation steps internal to a company, as well as the processes of external component suppliers. A breakdown in any link of the chain can undermine the reliability of an EPD, potentially subjecting the issuing companies to misrepresentation or contract liability.


Matt Johnson

Matt Johnson

Matt Johnson is a member of The Gary Law Group, a Portland-based firm specializing in legal and risk issues facing manufacturers of glazing products. He can be reached at