I was researching on some Electrical and Electronic Equipment EPDs and found one on EPD International. The PCR used was EPD International PCR 2024:06 - “Electronic and Electric Equipment, And Electronic Components (Nonconstruction) V1.01”. While reading this PCR, I noted that this PCR is non-compliant with EN15804+A2 (Conformance to this PCR does not ensure conformance with EN 15804+A2, nor with PCR 2019:14 on construction products. Many rules in this PCR are, however, aligned with EN 15804+A2), but EPD Mentions conformance with EN15804+A2.
I want to understand if a PCR is not compliant with EN15804 (However, there are some sections which are aligned with EN15804), can the EPD published using this PCR be compliant with EN15804+A2?
I also have some additional questions:
Can an EPD be published on The International EPD System using only EN15804+A2 as a core PCR, not their PCR 2019:14 - Construction Products, if the product or system falls under construction products?
Can EN15804+A2 be used as a Core PCR and PCR 2024:06 - “Electronic and Electric Equipment, And Electronic Components (Nonconstruction) V1.01” as c-PCR?
I appreciate your responses and guidance in this regard. Thankyou in advance.
@Aniket_Kumar Questions often arise when reviewing EPDs for electrical and electronic equipment, particularly when an EPD references a PCR that states it is not compliant with EN 15804, yet the EPD itself claims conformity with EN 15804+A2. To understand whether this is technically correct, it is important to clarify the roles of EN standards and Product Category Rules (PCRs).
EN 15804 is a European harmonised standard developed by CEN. It functions as a core Product Category Rule (core PCR) for construction products under the Construction Products Regulation (CPR). In practice, EN 15804 ensures methodological consistency and comparability of EPDs for construction products usually across Europe. If an EPD claims compliance with EN 15804+A2, it must follow this structure and its methodological requirements.
A PCR provides product-category-specific rules for developing an EPD. Within The International EPD System, the hierarchy for construction products typically consists of:
EN 15804+A2 – Core standard
PCR 2019:14 Construction Products – Programme-specific PCR
Complementary PCR (c-PCR) – Product-specific rules, where applicable
For construction products published under The International EPD System, EN 15804+A2 and PCR 2019:14 must both be applied.
PCR 2024:06 – “Electronic and Electric Equipment, and Electronic Components (Nonconstruction)” – explicitly states that conformance with this PCR does not ensure conformance with EN 15804+A2.
This is because:
It is intended for non-construction electrical and electronic equipment.
It is not structured around the EN 15804 modular system.
It may not require reporting of all EN 15804+A2 impact indicators.
It does not follow the methodological framework required for construction products.
Therefore, if an EPD is developed solely under PCR 2024:06, it cannot automatically claim EN 15804+A2 compliance.
An EPD may claim EN 15804+A2 compliance only if:
The product qualifies as a construction product, and
The EPD is developed in accordance with:
EN 15804+A2, and
PCR 2019:14 (under The International EPD System)
An EPD developed under a non-construction PCR cannot claim EN 15804+A2 compliance unless it demonstrably follows EN 15804+A2 and the relevant programme PCR requirements.
I appreciate and thankyou for your response and this elaborated guidance. It indeed enhanced my understanding of PCRs, core Rules and standards applicability.
