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Current product-specific EPDs depend on new fenestration PCR

Understanding MRc2 Option 1, and a new product category rule for fenestration

Glazing contractors are well aware that very few manufacturers have been able to offer them current product-specific Environmental Product Declarations (EPDs) for aluminum-framed entrance, storefront, curtain wall, window or other fixed fenestration systems. We’re optimistic that this will soon change and will better support projects seeking U.S. Green Building Council (USGBC) LEED v4.1 certification.

Our June 2022 blog  on deciphering LEED credits discussed compliance paths as they related to satisfying the Materials and Resources Building Product Disclosure and Optimization – EPD credit (MRc2). Today, let’s focus on compliance Option 1 and the declaration method associated with product-specific EPDs.

Compliance Option 1 and the declaration method

To qualify for the MRc2 Option 1, USGBC’s credit guidelines  state your project must “use at least 20 different permanently installed products from at least five different manufacturers that meet one of the disclosure criteria.” Among these choices is:

“Environmental Product Declarations which conform to ISO 14025 and EN 15804 or ISO 21930 and have at least a cradle-to-gate scope. Product-specific Type III EPD – Products with third-party certification (Type III), including external verification and external critical review are valued as 1.5 products for the purposes of credit achievement calculation.”

For manufacturers to develop their comprehensive product-specific EPDs, a Product Category Rule (PCR) document is needed first. The predominant cradle-to-gate PCR used by fenestration manufactures to generate their own product-specific EPDs expired in 2020.

An extension was granted through September 2021. A new fenestration PCR has been needed ever since, but the company that had served as the PCR program operator is now defunct. As a result, fenestration manufacturers have not been able to provide the documentation to support the relevant LEED v4.1 EPD credit.

New PCR for fenestration assemblies

To meet this need, NSF International’s National Center for Sustainability Standards (NCSS ) has collaborated with the Fenestration and Glazing Alliance (FGIA ), National Glass Association (NGA ) and Window & Door Manufacturers Association (WDMA ). Together, they have developed a PCR for Fenestration Assemblies. This PCR addresses multiple sustainability attributes and performance areas throughout the fenestration lifecycle.

NSF NCSS assembled a multi-company panel of industry-leading members to help author the PCR. Tubelite is one of the 12 participating companies that provided input as to specific metrics needed for the fenestration products covered, as well as which products this PCR would address moving forward. The first draft of this PCR was completed and voted on by the panel members for adoption. That draft was adopted and a public comment period was open through August 21, 2023. 

Moving forward, any negative comments requiring revision will need to be resolved. Once those revisions are completed, the PCR can then be published in four to six weeks.

It’s anticipated the fenestration industry will have a new PCR framework to draft product-specific EPDs before the end of 2023.


Mary Avery

Mary Avery

Mary Avery serves as vice president of marketing for Tubelite, Alumicor and Linetec brands. Commercial glazing contractors have depended on Tubelite’s architectural aluminum products for more than 75 years. Learn more at