PACKAGING PCR Epd
PACKAGING PCR Epd
PACKAGING PCR Epd
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
PCR 2019:13
VERSION 1.1.2
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
TABLE OF CONTENTS
TABLE OF CONTENTs ........................................................................................................................................................................ 2
1 Introduction ................................................................................................................................................................................. 3
4 Goal and scope, life cycle inventory and life cycle impact assessment ...................................................................................... 12
6 Glossary .................................................................................................................................................................................... 27
7 References ................................................................................................................................................................................ 28
ANNEX 3 – Examples of packaging products and how to use this PCR ............................................................................................. 32
ANNEX 4 – Examples of MULTI-MATERIAL packaging products and how to use this PCR ............................................................... 38
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
1 INTRODUCTION
This document constitutes Product Category Rules (PCR) developed in the framework of the International EPD® System: a programme
for type III environmental declarations1 according to ISO 14025:2006. Environmental Product Declarations (EPDs) are voluntary
documents for a company or organisation to present transparent information about the life cycle environmental impact for their goods
or services.
The rules for the overall administration and operation of the programme are the General Programme Instructions, publicly available at
www.environdec.com. A PCR complements the General Programme Instructions and the standards by providing specific rules,
requirements and guidelines for developing an EPD for one or more specific product categories (see Figure 1). A PCR should enable
different practitioners using the PCR to generate consistent results when assessing products of the same product category.
Figure 1 Illustration of PCR in relation to the hierarchy of standards and other documents.
For the definition of terms used in the document, see the normative standards.
A PCR is valid for a pre-determined period of time to ensure that it is updated at regular intervals. The latest version of the PCR is
available via www.environdec.com. Stakeholder feedback on PCRs is very much encouraged. Any comments on this PCR document
may be given via the PCR Forum at www.environdec.com or sent directly to the PCR moderator during its development or during the
period of validity.
Any references to this document should include the PCR registration number, name and version.
The programme operator maintains the copyright of the document to ensure that it is possible to publish, update when necessary, and
available to all organisations to develop and register EPDs. Stakeholders participating in PCR development should be acknowledged
in the final document and on the website.
1
Type III environmental declarations in the International EPD® System are referred to as EPD, Environmental Product Declarations.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
2 GENERAL INFORMATION
Programme:
Programme operator: EPD International AB, Box 210 60, SE-100 31 Stockholm, Sweden.
Website: www.environdec.com
E-mail: info@environdec.com
PCR Moderator: Anna Bortoluzzi, Università degli Studi di Milano - Department of Chemistry,
anna.bortoluzzi@quotasette.it
PCR Committee: ApE-PACKAGING WORKING GROUP (Università degli Studi di Milano - Department of
Chemistry -- http://www.ape.unimi.it/lca-studies/), QUOTA SETTE Srl
Schedule for renewal: A PCR is valid for a pre-determined period of time to ensure that it is updated at regular
intervals. When the PCR is about to expire the PCR moderator shall initiate a discussion with
the Secretariat how to proceed with updating the document and renewing its validity.
A PCR document may be revised during its period of validity provided significant and well-
justified proposals for changes or amendments are presented. See www.environdec.com for
up-to-date information and the latest version.
Standards conformance: General Programme Instructions of the International EPD® System, version 3.0, based on ISO
14025 and ISO 14040/14044
PCR language(s): This PCR was developed and is available in English. In case of translated versions the English
version takes precedence in case of any discrepancies.
That is why this document has been developed through a multi-code (UN CPC codes) and multi-material approach. The framework of
the document is based on the main functions of packaging as stated in the ISO definition. "Packaging": product to be used for the
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
containment, protection, handling, delivery, storage, transport and presentation of goods, from raw materials to processed goods,
from the producer to the user or consumer, including processor, assembler or other intermediary.
This PCR has been developed with a modular approach regarding the life cycle stages and the system boundaries definition. A
declared unit is based on technical characteristics relevant for any packaging purpose and is extendable to a functional unit to include
intended use, use phase and end-of-life.
The chart below shows the main functions of packaging and allows for a first general classification of packaging products (source of
definitions: ISO 21067-1).
Below are reported the terms and definitions relevant to this PCR, taken from the ISO standards that apply to packaging (e.g. ISO
21067-1, ISO 21067-2, ISO 18601):
▪ packaging (product): product to be used for the containment, protection, handling, delivery, storage, transport and presentation
of goods, from raw materials to processed goods, from the producer to the user or consumer, including processor, assembler
or other intermediary
▪ packaging (operation): operations involved in the preparation of goods for containment, protection, handling, delivery, storage,
transport and presentation of goods, from raw materials to processed goods, from the producer to the user or consumer
▪ primary packaging: packaging designed to come into direct contact with the product
▪ secondary packaging: packaging designed to contain one or more primary packaging together with any protective materials
where required
▪ packaging component: part of packaging that can be separated by hand or by using simple physical means
▪ packaging constituent: part from which packaging or its components are made and which cannot be separated by hand or by
using simple physical means [SOURCE: ISO 18601]
▪ reuse: operation by which packaging is refilled or used for the same purpose for which it was conceived, with or without the
support of auxiliary products present on the market enabling the packaging to be refilled.
▪ reusable packaging: packaging or packaging component which has been designed to accomplish or proves its ability to
accomplish a minimum number of trips or rotations in a system for reuse
Note 1: In order to be considered reusable, a packaging product must possess specific characteristics, documented in the
product technical specifications. In any case, reusability must be identified as a designed-in property of the product. Further
definitions related to reuse are given in Annex 2.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
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PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ recyclable: characteristic of a product, packaging or associated component that can be diverted from the waste stream through
available processes and programmes and can be collected, processed and returned to use in the form of raw materials or
products
The framework of this document is based on the main functions of packaging as stated in the ISO definition 2. The product group
definition is therefore: "Packaging" product to be used for the containment, protection, handling, delivery, storage, transport and
presentation of goods, from raw materials to processed goods, from the producer to the user or consumer, including processor,
assembler or other intermediary.
All packaging products, which fall under the above reported ISO definitions, are included in the scope of the PCR independently of their
material composition, dimensions or service life. In general, all products that are covered by a harmonized standard according to the
packaging products regulation (or the earlier packaging products directive) could, however, be considered as packaging. Some
examples of packaging products are provided in Annex 3.
Note 2: A product is considered packaging if it performs all or part of the functions included in the definition of packaging given above.
This PCR covers both packaging products intended for single use and products destined for reuse, provided they have been explicitly
designed for multiple use cycles.
The recycling of a product for the same original purpose, after transformation into secondary raw material, is not considered reuse, and,
as such, does not fall within the scope of this PCR. Reuse by the consumer that changes the purpose of the original packaging (for
example the domestic use of containers designed to be managed exclusively on industrial lines) is outside of the scope of this PCR. In
these cases it is not possible to guarantee the same levels of safety envisaged in the packaging design.
Also outside the scope of this PCR are all products that are not usable for the handling of goods and are thus not covered by the
definition of packaging as stated above. Moreover, environmental impacts related to the product contained in the packaging (goods,
food, etc.) are outside the purpose of this PCR.
Note 3: According to the General Programme Instructions, this PCR may contain information on the potential benefits gained from the
end-of-life recycling of a product covered by an EPD (see par. 5.4.6)
As this PCR covers a very generic product category, with a wide range of packaging products, it is difficult to classify according to UN
CPC classification. The UN CPC codes on packaging have the following drawbacks:
To overcome these structural problems in the UN CPC classification, a three-step model has been developed (Figure 3), which allows
to easily identify the most appropriate CPC code for each packaging product. A few examples are provided in Table 1, and the typical
cases occurring most often are considered in Annex 3.
2
ISO 21067-1, Packaging – Vocabulary- Part 1: general terms
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Figure 3 “3-step diagram” of the procedure for finding the correct CPC code.
The UN CPC codes given below have been obtained using the 3-step approach (Figure 3). They are a non-exhaustive list; other CPC
codes may also be relevant for this PCR.
STRUCTURAL PACKAGING
It can also be defined as distribution packaging or transport packaging (tertiary packaging as informal definition)
PACKING CASES, BOXES, CRATES, DRUMS AND SIMILAR 317 – 32153– 364 - 422
PACKINGS
COMMERCIAL PACKAGING
It includes 2 categories: industrial packaging and consumer packaging (primary and secondary packaging as informal definition)
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
BOTTLES, JARS, PHIALS, BARRELS, TINS, CANS, TUBES 37191 – 364 – 422
AND OTHER CONTAINERS OF A KIND USED FOR THE
CONVEYANCE OR PACKING OF GOODS
Table 1 Examples of CPC codes identified using the 3-step diagram (non-exhaustive list)
In case of special types of packaging, for which it turns out impossible to assign a CPC code with an adequate description using the
above 3-step logic flow, in the EPD a generic CPC code (e.g. 364 – Packaging products of plastics), or any other definition according
with international standards, will be assigned to the packaging in question.
In case of multi-material packaging, the CPC code is chosen based on the most prevalent material.
Furthermore, during the preparation of an EPD for a packaging product, the following rules shall be taken into account:
▪ In case of complex sales units, it will be possible to prepare a single EPD only in those cases where the packaging constituent
(that is, the main part of the packaging product) can be singled out. The packaging constituent performs the packaging function
and can be assembled with packaging components (other parts of the packaging product) which perform specific functions,
such as stoppers and lids. Indeed, the role of packaging components is to complete the sales unit and they are considered
auxiliary materials subject to supply. (See definitions in section 2.2.1).
▪ In case of complex sales units (requiring, for instance, both primary and secondary packaging), several EPDs may be needed if
a number of processes are involved in the production of the various types of packaging that make up the sales unit.
▪ In the special case of consumer packaging, where the user takes on the responsibility for packaging co-design and packaging
making in the final packaging forming and/or assembly phases, the packaging user can be equated to the packaging
manufacturer, and thus, in this case, may be an EPD Owner.
▪ In the special case of consumer packaging, two approaches to the publication of EPDs can be envisioned: EPDs prepared by
single packaging manufacturers restricted to the packaging constituents/components under their responsibility, and EPDs
prepared by the packaging user, who can demonstrate its role in the core processes and prepares the EPD on the consumer
packaging sales unit.
Some examples for the application of the above rules are given in Annex 4.
Regardless of the intended use and classification of distribution, industrial or consumer packaging, an EPD can be also prepared for a
packaging component such as a cap or a closure film for a container.
▪ The product stage only. Such an EPD covers raw material supply, transport, manufacturing and associated processes; this
EPD is said to be “cradle-to-gate” and becomes an EPD based on information modules A1 to A3 (see par. 4.3.1).
▪ The product stage and selected further life cycle stages. Such an EPD is said to be “cradle-to-gate with options” and becomes
an EPD based on information modules A1 to A3 plus other selected optional modules, e.g. end-of-life information modules C1
to C3. (see par. 4.3.1).
▪ The life cycle of a product according to the system boundary. In this case, the EPD covers the product stage, use and
maintenance, waste processing for reuse, recovery, recycling and disposal and is said to be “cradle-to-grave”. It becomes a
packaging product EPD based on an LCA, i.e., covering all information modules A1 to C3. (see par. 4.3.1).
Note 4: the ”cradle to gate with options” approach was introduced to allow the EPD owner to enter information relating to the
environmental impacts of certain phases of the downstream module on which the company assumes strategic to insert information.
This without having the obligation to quantify the impacts for the entire downstream stage.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
In the case of consumer packaging or reusable packaging3, a “cradle-to-grave” LCA with a functional unit shall be performed. This
requirement does not apply for the preparation of an EPD relating to a consumer packaging component such as a cap or a closure
film for a container.
Figure 4 Choice of functional/declared unit and system boundaries based on the packaging product covered by an EPD.
An EPD shall be updated and re-verified during its validity if changes in technology or other circumstances have led to:
▪ significant changes to the declared product information, content declaration, or additional environmental information.
If such changes have occurred, but the EPD is not updated, the EPD owner shall contact the Secretariat to de-register the EPD.
3
See the definition of reusable packaging in section 2.2.1.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
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PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
PCR review panel: The Technical Committee of the International EPD® System. A full list of members available on
www.environdec.com. The review panel may be contacted via info@environdec.com.
Members of the Technical Committee were requested to state any potential conflict of interest with the
PCR moderator or PCR committee, and were excused from the review.
Stakeholders were invited via e-mail or other means to take part in the open consultation, and were encouraged to forward the invitation
to other relevant stakeholders. The following stakeholders provided comments during the open consultation, and agreed to be listed as
contributors to the PCR and at www.environdec.com:
▪ Fabrice Rivet & Romeo Pavanello, FEVE - The European Container Glass Federation
▪ GlobalEPD
▪ EPD Norway
▪ IBU
▪ PEP ecopassport®
▪ EarthSure
▪ EDF
▪ JEMAI EcoLeaf
▪ UL Environment
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ DAPcons®
These already existing PCRs on the packaging sector can potentially remain valid as stand-alone PCRs and can be gradually made
compliant with this PCR.
▪ PEF Working Group, Packaging Working Group guidance document, Ver. 1.0, May 2016
▪ Sustainable Packaging Coalition, Definition of Sustainable Packaging, Ver. 2.0, August 2011
▪ UNEP Life Cycle Initiative, An Analysis of Life Cycle Assessment in Packaging for Food & Beverage Applications, 2013
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
The following technical information supports the declared unit definition and shall be reported in the EPD, if applicable:
▪ Compression values (e.g. results of the compression test based on ISO 12048 or equivalent)
▪ Stacking values (e.g. results of the stacking test based on ISO 12048 or equivalent).
The declared unit shall be stated in the EPD. The environmental impact shall be given per declared unit. A description of the function
of the product should be included in the EPD, if relevant.
The packaging application (the sector(s) in which the packaging can be used and the types of content it is suitable for) and use (the
types of technology that are suitable) shall be clearly declared in the EPD.
The following technical information supports the functional unit definition and shall be reported in the EPD, if applicable:
▪ Compression values (e.g. results of the compression test based on ISO 12048 or equivalent)
▪ Stacking values (e.g. results of the stacking test based on ISO 12048 or equivalent).
In case a functional unit (cradle-to-grave LCA) is used, the following information shall also be included in order to increase comparability:
4
See the definition of reusable packaging at 2.2.1
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
An optional additional functional unit may be used, taking into consideration the quantity of volume transported in the life cycle of the
packaging and should be declared as total volume or its units. The numbers of reuses and the total volume considered shall be
declared in the EPD.
For two-dimensional (flat) products such as films or sheet an alternative declared/functional unit of 1 (one) m2 of product with the related
thickness and unit weight in g/m2 may be used only if the EPD owner is not able to identify the final packaging product unit such as in
the case of industrial packaging sold without branded printing5.
Note 5: In the case of reusable packaging, the number of uses declared in the EPD must coincide with the legal approval of the product
and/or the supply specifications. If this information is not available from the abovementioned sources, the indicator for the reconditioning
of all the packaging parts in the rotation cycles (restoration) shall be used. Rotation is defined6 as the cycle undergone by reusable
packaging from filling/loading to filling/loading.
Note 6: The number of reuses depends on safety aspects and the use of filling/reuse technologies.
The scope of this PCR and EPDs based on it is cradle to gate, cradle to gate with options or cradle to grave.
In this PCR an additional division of the three main life cycle stages is used and is based on “life cycle modules” A1-C3.
This PCR allows for an optional LCA scope reported in the EPD:
▪ a “cradle-to-gate with options” EPD: Modules A1 to A3 plus other selected optional modules, e.g. end-of-life modules C1 to C3
In the EPD, the environmental performance associated with each of the three life cycle stages above shall be reported separately. The
environmental performance associated with each of the modules considered (from A1 to C3) may be reported separately.
In some cases, certain modules may not be relevant to the environmental performance of a product. In such cases, the irrelevant
module shall be declared as “Module Not Declared, MND”. Such a declaration shall not be regarded as an indicator result of zero.
5
flat packaging products can be sold preformed or in the form of reels or flat sheets but, in any case, they are all designed for
containment, protection, handling, delivery, storage, transport and presentation of goods even if the final function is not necessarily
performed in the same phase of the life cycle. For consumer packaging, in most cases, the package (product unit) is clearly
identifiable since it coincides with the printed image and therefore the declared/functional unit shall be 1 packaging product unit so as
to maximize comparability with similar products, having the same application. In the case of industrial packaging, where there is no
print that identifies the package and the packaging product can be used for various applications, the alternative declared/functional
unit of 1 m2 may be used.
6
ISO 21067-2:2016, Packaging – Vocabulary- Part 2: Packaging and the environment terms
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Life cycle stage Life cycle module Life cycle module group EPD type
Cradle-Gate
with options
(*) Both phase A3 and phase A5 (if present) are to be considered packaging production phases. In fact, packaging production is
considered completed only upon conclusion of all the phases that will allow the product to accomplish its final function for the
intended use.
(**) Reconditioning7: operations necessary to restore a reusable packaging to a functional state for further reuse.
Table 2 The life cycle of a packaging product divided into three life cycle stages according to the General Programme Instructions and
four life cycle module groups
When the Forming processes (A5), or one of their phases, are performed concurrently (e.g. on the same production line or in the same
plant) with the Filling processes (B1), the environmental impacts from both processes shall be included in the system boundaries.
As reported at section 2.2.2, the EPD can be issued both by the single packaging manufacturer and by the packaging user. These two
cases evidently present a different system boundary setting, mainly for the life cycle modules A3 and A5, depending on the real situation
taken into consideration for the preparation of the LCA model. Furthermore, there may also be other cases that require adapting the
system boundaries in accordance with the production processes of the specific supply chain, always in compliance with the rules of this
PCR.
In the case of reusable packaging, only one reuse cycle shall be considered in the LCA calculation (from A1 to B5), and not all the uses
of the reusable packaging during its lifetime, because it mainly depends on the customer’s choices. In order to enable comparability for
reusable packaging, it is mandatory to declare in the EPD all the technical information listed and the number of uses of the reusable
packaging during its lifetime, as reported in paragraph 4.1.2.
The processes included in the scope of the PCR and belonging to each life cycle stage are described in Sections 4.3.1.1–4.3.1.3.
A few examples of system boundary definitions for specific packaging products are given in Annex 3.
The following attributional processes are part of the product system and classified as upstream processes:
7
ISO 21067-2:2016, Packaging – Vocabulary - Part 2: Packaging and the environment terms
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PRODUCT CATEGORY RULES (PCR)
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PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Extraction of resources
▪ Recycling processes of secondary materials from a previous product system (e.g. plastics recycling)8
▪ Refinement of resources
▪ Impacts due to the production of electricity and fuels used in the upstream module
Upstream processes not listed may also be included. All elementary flows at resource extraction shall be included, except for the flows
that fall under the general cut-off rule in Section 4.5.
The following attributional processes are part of the product system and classified as core processes:
A2) Transportation
A3) Manufacturing
▪ Production of additives used in auxiliary core processes (e.g. chemicals for internal plant water treatment)
▪ Impacts due to the production of electricity and fuels used in the core module
Manufacturing processes not listed may also be included. The production of the raw materials used for production of all product parts
shall be included. A minimum of 99% of the total weight of the declared product including packaging9 shall be included.
The following attributional processes are part of the product system and classified as downstream processes:
A4) Transport
8
Not including those processes that are part of waste processing in the previous product system, referring to the “polluter pays
principle”.
9
This refers to the packaging of the packaging product under study.
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PRODUCT CATEGORY RULES (PCR)
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PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Filling of the packaging unit with any kind of matter in any physical state (liquid, solid, or gas), including any packaging
closing/welding operations.
▪ The energy consumption, the production of the packaging components (e.g. lid, closing film) and the packaging material
wasted in the filling process shall be included.
Note 7: The environmental impacts related to the distribution of the filled packaging shall be allocated to the packaging and to the
transported product (without packaging) according to their masses. The burden related to the distribution of the content of the
packaging is then excluded from the environmental impacts of the distribution of the filled packaging.
B4) Reconditioning
▪ Operations necessary to restore a reusable packaging to a functional state for further reuse. Reconditioning covers the
combination of all typically planned technical and associated administrative activities and actions during the service life.
Note 8: In the case of reusable packaging, only one reuse cycle shall be considered in the LCA calculation.
C1) Disassembling/sorting
▪ Operations for the separation of packaging product components and subsequent sorting.
Transportation of the discarded product accounts for part of waste processing, e.g. to a recycling site or to final sorting yard or
disposal
Note 9: A packaging product becomes waste when all the functions that it can perform and that are clearly stated in the definition of
packaging have been exhausted.
▪ Waste disposal including physical pre-treatment and management of the disposal site. Emissions from waste disposal are
considered part of the product system under study and therefore are part of this module, according to the “polluter pays
principle”.
Boundaries to nature are defined as flows of material and energy resources from nature into the system. Emissions to air, water and
soil cross the system boundary when they are emitted from or leaving the product system.
See Section 4.3.1. The EPD may present the information divided into additional sub-divisions.
10
Only if final forming is outside of the company boundaries.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
A system diagram of the processes included in the LCA for the specific packaging product, divided into life cycle stages, shall be
reported in the EPD.
The check for cut-off rules in a satisfactory way is through the combination of expert judgment based on experience of similar product
systems and a sensitivity analysis in which it is possible to understand how the un-investigated input or output could affect the final
results.
1. Allocation shall be avoided, if possible, by dividing the unit process into two or more sub-processes and collecting the
environmental data related to these sub-processes.
2. If allocation cannot be avoided, the inputs and outputs of the system shall be partitioned between its different products or
functions in a way that reflects the underlying physical relationships between them; i.e. they should reflect the way in which the
inputs and outputs are changed by quantitative changes in the products or functions delivered by the system.
3. Where physical relationship cannot be established or used as the basis for allocation (or they are too time consuming), the inputs
should be allocated between the products and functions in a way that reflects other relationships between them. For example,
input and output data might be allocated between co-products in proportion to the economic value of the products. If the economical
allocation has been used, a specific sensitivity analysis shall be provided to the verifier and the monitoring of the relationship
between results and current economic value shall be documented and updated. The allocation method shall be justified and
described in the LCA report. In case an allocation different from the physical relationship allocation is used, it shall be declared in
the EPD.
▪ data related to the environmental aspects of the considered system (such materials or energy flows that enter the production
system). These data usually come from the company that is performing the LCA calculation.
▪ data related to the life cycle impacts of the material or energy flows that enter the production system. These data usually
come from databases.
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PRODUCT CATEGORY RULES (PCR)
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PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Data on environmental aspects shall be as specific as possible and shall be representative of the studied process.
Data on the life cycle of materials or energy inputs are classified into three categories – specific data, selected generic data, and
proxy data, defined as follows:
▪ specific data (also referred to as “primary data” or “site-specific data”) – data gathered from the actual manufacturing plant
where product-specific processes are carried out, and data from other parts of the life cycle traced to the specific product
system under study, e.g. materials or electricity provided by a contracted supplier that is able to provide data for the actual
delivered services, transportation that takes place based on actual fuel consumption, and related emissions, etc.,
- selected generic data – data from commonly available data sources (e.g. commercial databases and free databases)
that fulfil prescribed data quality characteristics for precision, completeness, and,
- proxy data – data from commonly available data sources (e.g. commercial databases and free databases) that do not
fulfil all of the data quality characteristics of “selected generic data”.
As a general rule, specific data shall always be used, if available, after performing a data quality assessment. It is mandatory to use
specific data for the core processes as defined above. For the upstream processes, downstream processes, and infrastructure,
generic data may also be used if specific data are not available.
Any data used should preferably represent average values for a specific reference year. However, the way these data are generated
could vary, e.g. over time, and in such cases they should have the form of a representative annual average value for a specified
reference period. Such deviations should be declared.
▪ the reference year must be as current as possible and preferably assessed to be representative for at least the validity period
of the EPD,
▪ the cut-off criteria to be met on the level of the modelled product system are the qualitative coverage of at least 99% of energy,
mass, and overall environmental relevance of the flows,
▪ completeness in which the inventory data set should, in principle, cover all elementary flows that contribute to a relevant degree
of the impact categories, and
▪ the representativeness of the resulting inventory in the given temporal, technological, and geographical reference should, as a
general principle, be better than ±5% of the environmental impact of fully representative data.
Section 4.8 provides a list of recommended databases/data sets to be used for generic data.
If selected generic data that meets the requirements of the International EPD® System are not available as the necessary input data,
proxy data may be used and documented. The environmental impacts associated with proxy data shall not exceed 10% of the overall
environmental impact from the product system.
The EPD may include a data quality declaration to demonstrate the share of specific data, selected generic data and proxy data for the
environmental impacts.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Data referring to processes and activities upstream in a supply chain over which an organisation has direct management
control shall be specific and collected on site.
▪ Data referring to contractors that supply main parts, packaging, or main auxiliaries should be requested from the contractor as
specific data.
▪ The transport of main parts and components along the supply chain to a distribution point (e.g. a stockroom or warehouse)
where the final delivery to the manufacturer can take place based on the actual transportation mode, distance from the
supplier, and vehicle load.
▪ In case specific data is lacking, selected generic data may be used. If this is also lacking, proxy data may be used.
▪ For the electricity used in the upstream processes, electricity production impacts shall be accounted for in this priority when
specific data are used in the upstream processes:
1. Specific electricity mix as generated, or purchased, from an electricity supplier, demonstrated by a Guarantee of Origin
(or similar, where reliability, traceability, and the avoidance of double-counting are ensured) as provided by the electricity
supplier. If no specific mix is purchased, the residual electricity mix from the electricity supplier shall be used. 11
The mix of electricity used in upstream processes shall be documented in the EPD, where relevant.
▪ Specific data shall be used for the assembly of the product and for the manufacture of main parts as well as for on-site
generation of steam, heat, electricity, etc., where relevant.
▪ For the electricity used in the core processes, electricity production impacts shall be accounted for in this priority:
1. Specific electricity mix as generated, or purchased, from an electricity supplier, demonstrated by a Guarantee of Origin
(or similar, where reliability, traceability, and the avoidance of double-counting are ensured) as provided by the electricity
supplier. If no specific mix is purchased, the residual electricity mix from the electricity supplier shall be used. 12
The mix of electricity used in the core processes shall be documented in the EPD, where relevant.
▪ Transport from the final delivery point of raw materials, chemicals, main parts, and components (see above regarding upstream
processes) to the manufacturing plant/place of service provision should be based on the actual transportation mode, distance
from the supplier, and vehicle load, if available.
▪ Waste treatment processes of manufacturing waste should be based on specific data, if available.
11
The residual electricity mix is the mix when all contract-specific electricity that has been sold to other customers has been
subtracted from the total production mix of the electricity supplier.
12
The residual electricity mix is the mix when all contract-specific electricity that has been sold to other customers has been
subtracted from the total production mix of the electricity supplier.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ If the forming stage (A5) is considered to be within the system boundaries (final forming outside the company) specific data
shall be used for the forming stage (A5). In fact, packaging production is considered completed only upon conclusion of all the
phases that allow the product to perform its final function for the intended use.
▪ In the case of reusable packaging, only one reuse cycle shall be considered in the LCA calculation (from A1 to B5), and not all
the uses of the reusable packaging during its lifetime because it mainly depends on the customer’s choices. In order to enable
comparability for reusable packaging, it is mandatory to declare in the EPD all the technical information listed and the number
of uses of the reusable packaging during its lifetime, as reported in paragraph 4.1.2.
▪ Data for the use stage are usually based on scenarios, but specific data should be used when available and relevant.
▪ Data on the pollutant emissions from the use stage should be based on documented tests, verified studies in conjunction with
average or typical product use, or recommendations concerning suitable product use. Whenever applicable, test methods shall
be internationally recognised.
▪ The use of electricity in the region/country where the product is used (as specified in the geographical scope of the EPD) shall
be accounted for in the following order of priority:
1. Specific electricity mix as generated, or purchased, from an electricity supplier, demonstrated by a Guarantee of Origin
(or similar, where reliability, traceability, and the avoidance of double-counting are ensured) provided by the electricity
supplier. If no specific mix is purchased, the residual electricity mix from the electricity supplier shall be used. 13
The mix of electricity used in the downstream processes shall be documented in the EPD, where relevant.
▪ The transport of the product to the customer should reflect the actual situation to the best extent possible. The following priority
should be used:
2. Calculated as the average distance of a product of that product type transported by different means of transport modes.
3. Calculated as a fixed long transport, such as 1 000 km transport by lorry or 10 000 km by airplane, according to product
type.
▪ Scenarios for the end-of-life stage shall be technically and economically practicable and compliant with current regulations in
the relevant geographical region based on the geographical scope of the EPD. Key assumptions regarding the end-of-life stage
scenario shall be documented.
13
The residual electricity mix is the mix when all contract-specific electricity that has been sold to other customers has been
subtracted from the total production mix of the electricity supplier.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ shall be in line with the requirements and guidelines in ISO 14020 (Environmental labels and declarations - General principles),
▪ shall not include rating, judgements or direct comparison with other products.
An EPD should be made with a reasonable number of pages for the intended audience and use.
▪ The International System of Units (SI units) shall be used, e.g., kilograms (kg), Joules (J) and metres (m). Reasonable
multiples of SI units may be decided in the PCR to improve readability, e.g., grams (g) or megajoules (MJ). The following
exceptions apply:
- Resources used for energy input (primary energy) should be expressed as kilowatt-hours (kWh) or megajoules (MJ),
including renewable energy sources, e.g., hydropower, wind power and geothermal power.
- Time should be expressed in the units most practical, e.g., seconds, minutes, hours, days or years.
▪ Three significant figures14 should be adopted for all results, the number of significant digits shall be appropriate and consistent.
▪ The thousand separator and decimal mark in the EPD shall follow one of the following styles (a number with six significant
figures shown for illustration):
In case of potential confusion or intended use of the EPD in markets where different symbols are used, the EPD shall state
what symbols are used for thousand separator and decimal mark.
▪ Dates and times presented in the EPD should follow the format in ISO 8601. For years, the prescribed format is YYYY-MM-DD,
e.g., 2017-03-26 for March 26th, 2017.
- Only contain values or the letters “INA” (Indicator Not Assessed). It is not possible to specify INA for mandatory
indicators. INA shall only be used for voluntary parameters that are not quantified because no data is available. 15
- Contain no blank cells, hyphens, less than or greater than signs or letters (except “INA”).
- Use the value 0 only for parameters that have been calculated to be zero.
14
Significant figures are those digits that carry meaning contributing to its precision. For example with two significant digits, the result
of 123.45 shall be displayed as 120, and 0.12345 shall be displayed as 0.12. In scientific notation, these two examples would be
displayed as 1.2*102 and 1.2*10-2.
15
This requirement does not intend to give guidance on what indicators are mandated (“shall”) or voluntary.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ A note that “An EPD should provide current information, and may be updated if conditions change. The stated validity is
therefore subject to the continued registration and publication at www.environdec.com.”
16
The EPD shall not include a “registration number” if such is provided by the certification body, as this may be confused with the
registration number issued by the programme operator.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Address of programme operator: EPD International AB, Box 210 60, SE-100 31 Stockholm, Sweden, E-mail:
info@environdec.com
▪ The following mandatory statement from ISO 14025: “EPDs within the same product category but from different programmes
may not be comparable.”
▪ A statement that the EPD owner has the sole ownership, liability and responsibility of the EPD.
▪ The following statement: “The environmental impacts of different EPDs can be compared only taking into account all the
technical information supporting the declared/functional unit definition as requested by the PCR.”
▪ Only for reusable packaging, the following statement: "The calculated environmental impacts refer to only one reuse of the
packaging.”
▪ Information about verification17 and reference PCR in a table with the following format and contents:
Product category rules (PCR): <name, registration number, version and UN CPC code(s)>
PCR review was conducted by: <name and organisation of the review chair, and information on how to contact the chair through the
programme operator>
Independent third-party verification of the declaration and data, according to ISO 14025:2006:
Third party verifier: <name, organisation and signature of the third party verifier>
Procedure for follow-up of data during EPD validity involves third party verifier:
Yes No
▪ Description of the organisation. This may include information on products- or management system-related certifications (e.g.
ISO 14024 Type I environmental labels, ISO 9001- and 14001-certificates and EMAS-registrations) and other relevant work the
organisation wants to communicate (e.g. SA 8000, supply-chain management and social responsibility),
▪ Product identification by name, and an unambiguous identification of the product by standards, concessions or other means,
▪ Identification of the product according to the UN CPC scheme system. Other relevant codes for product classification may also
be included, e.g.
▪ Description of the product, its application/intended use and technical functions, e.g. expected service life time,
17
If the EPD has been verified by an approved individual verifier who has received contractual assistance from a certification body
that is not accredited, this certification body shall not be included in this table.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Geographical scope of the EPD, i.e., for which geographical location(s) of use and end-of-life the product’s performance has
been calculated,
▪ Functional unit or declared unit and all the applicable technical information (see 4.1.1 and 4.1.2),
▪ Declaration of the year(s) covered by the data used for the LCA calculation and other relevant reference years,
▪ Reference to the main database(s) for generic data and LCA software used, if relevant,
▪ System diagram of the processes included in the LCA, divided into the life cycle stages,
▪ Description if the EPD system boundary is “cradle-to-gate”, “cradle-to-gate with options” or “cradle-to-grave”,
▪ Information on which life cycle stages are not considered (if any), with a justification of the omission,
▪ Name and contact information of organisation carrying out the underlying LCA study,
▪ Additional information about the underlying LCA-based information, such as assumptions, cut-off rules, data quality and
allocation.
Information on the hazardous properties of materials and chemical substances should follow the requirements given in the latest
revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)18, issued by United Nations or
national or regional applications of the GHS.
As an example, the following regulations should be used for EPDs intended to be used in the European Union:
▪ Regulation (EC) No 1907/2006 of the European parliament and of the council of 18 December 2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
▪ Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling
and packaging of substances and mixtures
If the packaging product is for food contact, the Verifier shall check that the declaration of conformity is compliant with the intended
use. The declaration of conformity shall comply with applicable legislation and shall contain references to the substances potentially
released from the packaging.
When a product is made in whole or in part with recycled materials, the provenience of the materials (pre-consumer or post-
consumer) shall be presented in the EPD as part of the content declaration.
To avoid any misunderstanding about which material may be considered “recycled material”, the guidance given in ISO 14021 shall
be taken into account. In brief, the standard states that:
▪ only pre-consumer or post-consumer materials (scraps) shall be considered in the accounting of the recycled materials, and
▪ materials coming from scrap reutilisation (such as rework, regrind, or scrap generated in a process and capable of being
reclaimed within the same process that generated it) shall not be considered as recycled content.
18
The GHS document is available on www.unece.org.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
A statement of the source of the materials (pre-consumer or post-consumer) shall be presented in the EPD when the packaging is
made in whole or in part by recycled materials.
The EPD shall declare the environmental impact indicators, per declared/functional unit, per life-cycle stage and in aggregated form,
using the default impact categories, impact assessments methods and characterisation factors available at
www.environdec.com/indicators. The source and version of the impact assessment methods and characterisation factors used shall
be reported in the EPD.
Alternative regional life cycle impact assessment methods and characterisation factors may be calculated and displayed in addition to
the default list. If so, the EPD shall contain an explanation of the differences between the declared sets of indicators, as they may
appear to the reader to display duplicate information..
The EPD shall declare the mandatory, and may declare the optional, indicators for resource use listed at
www.environdec.com/indicators per declared/functional unit, per life-cycle stage and in aggregated form.
Waste generated along the whole life cycle production chains shall be treated following the technical specifications described in the
GPI. The EPD may declare the optional indicators for waste production and output flows as listed at www.environdec.com/indicators
per declared/functional unit, per life-cycle stage and in aggregated form.
The EPD may report other environmental indicators. Such indicators should be based on international standards or similar
methodologies developed in a transparent procedure. Reference to the chosen indicators and methodologies shall be reported.
An estimation of the avoided impacts/benefits related to material recycling may be made and declared separately as an additional
environmental indicator. Estimation methods used for calculating the avoided impacts shall be presented in the LCA report. Only
methods derived from LCA-based calculation shall be used.
▪ the release of dangerous substances into indoor air, soil, and water during the use stage, instructions for proper use of the
product, e.g. to minimise energy or water consumption or to improve the durability of the product,
▪ information on recycling including, e.g. suitable procedures for recycling the entire product or selected parts and
▪ information on a suitable method of reuse of the product (or parts of the products) and procedures for disposal as waste at the
end of its life cycle,
▪ information regarding disposal of the product, or inherent materials, and any other information considered necessary to
minimise the product’s end-of-life impacts, and
19
This refers to the packaging of the packaging product under study.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
- the existence of a quality or environmental management system or any type of organised environmental activity,
- any activity related to supply chain management, social responsibility, etc., and
- information on where interested parties may find more details about the organisation’s environmental work.
It is recommended to add information enabling the possibility to make comparisons with sector benchmarks or, if not available, with
benchmarks of common products and services preferably based on the concept of functional unit or declared unit, which is useful for
scaling the environmental impacts of different activities, products, and services.
A comparison between different EPDs can only be made for packaging products that perform the same function and the same
applications as reported in the technical data sheet (e.g., distribution conditions (chilled or ambient), possibility of pasteurization,
modified atmosphere, food contact).
▪ a description of how the selection of the sites/products has been done and how the average has been determined, and
▪ a statement that the document covers average values for an entire or partial product category (specifying the percentage of
representativeness) and, hence, the declared product is an average that is not available for purchase on the market.
▪ a description of the differences versus previously published versions, e.g. a description of the percentage change in results and
the main reason for the change;
5.4.9 REFERENCES
This section shall include a list of references, including the General Programme Instructions (including version number), standards
and PCR (registration number, name and version).
The executive summary should contain relevant summarised information related to the programme, product, environmental
performance, additional information, information related to sector EPDs, references and differences versus previous versions.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
6 GLOSSARY
AP Acidification potential
C2H4 Ethylene
kg kilogram
kWh kilowatt hour
UN United Nations
Sb Antimony
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
7 REFERENCES
CEN (2013), EN 15804:2012+A1:2013, Sustainability of construction works – Environmental product declarations – Core rules for the
product category of construction products.
EPD International (2017) General Programme Instructions for the International EPD® System. Version 3.0, dated 2017-12-11.
www.environdec.com
Guidance for Product Category Rule Development (2013), Ingwersen, W., Subramanian, V., editors. Product Category Rule
Guidance Development Initiative. Version 1.0. http://www.pcrguidance.org
ISO (2000), ISO 14020:2000, Environmental labels and declarations – General principles
ISO (2004), ISO 8601:2004 Data elements and interchange formats – Information interchange – Representation of dates and times
ISO (2006a), ISO 14025:2006, Environmental labels and declarations – Type III environmental declarations – Principles and
procedures
ISO (2006b), ISO 14040:2006, Environmental management – Life cycle assessment – Principles and framework
ISO (2006c), ISO 14044: 2006, Environmental management – Life cycle assessment – Requirements and guidelines
ISO (2013), ISO/TS 14067:2013, Greenhouse gases – Carbon footprint of products – Requirements and guidelines for quantification
and communication
ISO (2014), ISO 14046:2014, Environmental management – Water footprint – Principles, requirements and guidelines
ISO (2017), ISO 21930:2017, Sustainability in buildings and civil engineering works -- Core rules for environmental product
declarations of construction products and services
ISO 21067-2:2016, Packaging – Vocabulary - Part 2: Packaging and the environment terms
ISO 18601:2013, Packaging and the environment – General requirements for the use of ISO standards in the field of packaging and
the environment
PEF Working Group, Packaging Working Group guidance document, Ver. 1.0, May 2016
Sustainable Packaging Coalition, Definition of Sustainable Packaging, Ver. 2.0, August 2011
UNEP Life Cycle Initiative, An Analysis of Life Cycle Assessment in Packaging for Food & Beverage Applications, 2013
CAST Project, Guidelines for the application of the Regulation (EC) 2023/2006 to the supply chain of materials and articles intended
to come into contact with food, Rapporti ISTISAN 11/37
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ Inclusion in Section 2.2.2, Table 1 of an example of CPC codes for flat packaging products.
▪ Inclusion in Section 4.1.2 of an alternative declared/functional unit for two-dimensional (flat) products such as films or sheet.
▪ Clarification added in Section 4.3.1 about the different system boundary setting when the EPD owner is an individual
manufacturer or a packaging user.
▪ Editorial changes, including changes in Sections 5.4.5.1 to 5.4.5.3, to clarify the indicator list at www.environdec.com applies
also for the indicators of resource use, waste production and other output flows.
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ bag (or sack): flexible packaging of single or multiple layers or plies, generally enclosed on all sides except one, forming an
opening that may or may not be sealed after filling
▪ bale: shaped unit of compressed articles or materials bound with cord, strapping or metal ties under tension
▪ barrel (or cask or keg): packaging of circular cross-section, with greater length than breadth, with convex sides and two ends of
equal diameter
▪ bottle: rigid packaging, typically of glass or plastic, having a comparatively narrow neck or mouth, with a closure and usually no
handle
▪ ampoule: small packaging usually made of glass or plastic capable of being hermetically sealed
▪ box: rigid packaging with rectangular or polygonal sides, usually completely enclosing the contents
▪ case: non-specific term for transport packaging, often used to refer to a box
▪ wirebound box: box whose parts are reinforced and connected to each other by means of tempered wires
▪ bundle: number of articles bound with materials under tension, which also may be wrapped
▪ can: small primary packaging, usually cylindrical and usually made of metal
▪ drum: cylindrical packaging whose bottom end is permanently fixed to the body and top end (head) is either removable or non-
removable
▪ non-removable head drum (or tight head drum): cylindrical packaging whose ends are permanently fixed to the body, with one
or more openings for filling, emptying and venting in the top end (head) and which may also include body openings for the
same purposes
▪ removable head drum (or open head drum): drum whose bottom end is permanently fixed to the body and whose top end can
be removed as a lid (head)
▪ pail (or nesting drum): packaging of circular cross-section, tapered or cylindrical, and may be equipped with a lid and usually a
handle
▪ jerrycan: metal or plastics primary packaging of rectangular or polygonal cross-section for products
▪ tube: cylindrical packaging whose ends may be a different material to the body
▪ collapsible tube: flexible packaging having a nozzle and cap at one end and closed at the other, serving as both container and
dispenser
▪ tray: stiff layer material for dividing and holding multi packages
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PRODUCT CATEGORY RULES (PCR)
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ reuse: operation by which packaging is refilled or used for the same purpose for which it was conceived, with or without the
support of auxiliary products present on the market enabling the packaging to be refilled
▪ reusable packaging: packaging or packaging component which has been designed to accomplish or proves its ability to
accomplish a minimum number of trips or rotations in a system for reuse
▪ packaging used for the same purpose: packaging which, having completed a rotation, is subsequently reused with the original
conception, in a system for reuse
▪ reconditioning: operations necessary to restore a reusable packaging to a functional state for further reuse
▪ returnable packaging item RPI: any material used for the "protection" of goods during handling, delivery, storage and transport
that is returned for further usage
▪ returnable transport item RTI: any product for the purposes of transport, handling and/or distribution of one or more products or
product packages that are returned for further usage
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PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Wood pallet STRUCTURAL, PALLET WOOD 317(00) SINGLE USE DECLARED or - cradle-to-gate - Cutoff sawing
- or cradle-to-gate with - Debarking
FUNCTIONAL options - cutting to size
DISTRIBUTION
- or cradle-to-grave - Assembly and nailing
PACKAGING (§4.1.1, §4.1.2) - Printing
(§ 4.3)
NOTE
- A wood pallet is a typical example of structural packaging that can undergo several reuse cycles and for which reconditioning indicators are calculated as part of the logistics activities.
For wood pallets, reference should be made to the legal approval confirmed by a stamp, which indicates whether a pallet is approved for reuse.
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PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Folding carton COMMERCIAL, BOX (typical of PAPER 32153 SINGLE USE DECLARED or - cradle-to-gate - Deinking process
- or cradle-to-gate with - Mixture preparation
box (recycled) INDUSTRIAL commercial FUNCTIONAL options - Patina cooking
packaging), - or cradle-to-grave - Coating
(§4.1.1, §4.1.2) - Manufacturing (Paper Machine)
(§ 4.3)
CASE (typical of - Surface sizing
- Finish and setting up
COMMERCIAL, industrial packaging) SINGLE USE FUNCTIONAL cradle-to-grave
CONSUMER
(§4.1.2) (§ 4.3)
(§ 4.3 - the above processes are
typically A3)
NOTE
- A folding carton box is often combined with other packaging to form a pluripack (e.g. a carton box containing 3 pieces to make a single sales unit).
This PCR recommends that the various components of a pluripack should be treated as independent packaging and, as such, each should have its own EPD (par. 2.2.2).
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PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Glass bottle COMMERCIAL, BOTTLE GLASS 37191 SINGLE USE DECLARED or - cradle-to-gate - Proportioning of glass batch
- or cradle-to-gate with - Melting of raw materials and refining
INDUSTRIAL FUNCTIONAL options - Thermal conditioning of the molten
- or cradle-to-grave glass
(§4.1.1, §4.1.2) - Gob-cutting of melted glass and
(§ 4.3)
forming
- Annealing
REUSABLE FUNCTIONAL cradle-to-grave - Quality control
- Packaging/ palletting
(§4.1.2) (§ 4.3)
COMMERCIAL, SINGLE USE FUNCTIONAL cradle-to-grave (§ 4.3 - the above processes are
CONSUMER typically A3)
(§4.1.2) (§ 4.3)
(§4.1.2) (§ 4.3)
NOTE
- A glass bottle is sometimes designed in collaboration with the company-user in such a way as to foster brand recognition through an exclusive shape. In such cases, the company-user of the packaging controls both the
design phase and the final forming phase, and may therefore be an EPD Owner (par. 2.2.2)
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PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Three-piece COMMERCIAL, CAN METAL, STEEL 4293 SINGLE USE FUNCTIONAL cradle-to-grave - Preparation of the metallic laminate
- Lithopainting of the laminate foil (or
can CONSUMER utilization of raw tinplate)
(§4.1.2) (§ 4.3)
- Electro welding of the metal cylinder
- Junctions’ protection with coatings and
drying
- Moulding of the electrowelded cylinder
- Seam lidding
- Packing, labelling
NOTE
- A three-piece can is often combined with other types of packaging to form a pluripack (example, a folding carton box used to assemble 3 pieces into a single sales unit).
This PCR recommends that the various components of a pluripack should be treated as independent packaging and, as such, each should have its own EPD (par. 2.2.2).
PAGE 35/39
PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
PET Bottle COMMERCIAL, BOTTLE PLASTIC 36490 SINGLE USE FUNCTIONAL cradle-to-grave - Polymer dehumidifying
- Injection moulding
CONSUMER
(§4.1.2) (§ 4.3) (§ 4.2- the above processes are typically
A3)
- Blow moulding
(§ 4.3 - the above processes are
typically A5)
NOTE
- A PET bottle is sometimes co-designed in collaboration with the company-user, in such a way as to foster brand recognition through an exclusive shape and/or special labelling and can be classified as consumer packaging.
In such cases, the company-user of the packaging controls both the design phase and the final forming phase and may therefore be an EPD Owner (par.2.2.2).
PAGE 36/39
PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
Collapsible COMMERCIAL, TUBE METAL, 4299 SINGLE USE FUNCTIONAL cradle-to-grave - Impact extrusion
- Trimmer and threading
tube or multi- CONSUMER ALUMINIUM - Annealing of aluminium and lubricant
(§4.1.2) (§ 4.3)
layer sublimation
collapsible - Internal lacquering
- Coating enamel application
tube - Offset printing
- Cap application
- Latex-ring application
- Waxing and conical shape
process
- Packing
- Labelling
(§ 4.3- the above processes are typically
A3)
NOTE
- A collapsible tube is sometimes co-designed in collaboration with the company-user, in such a way as to foster brand recognition through an exclusive shape and/or special labelling and can be classified as consumer
packaging. In such cases, the company-user of the packaging controls both the design phase and the final forming phase and may therefore be an EPD Owner (par. 2.2.2).
PAGE 37/39
PRODUCT CATEGORY RULES (PCR) - DRAFT
DATE 2023-11-10
PACKAGING
PRODUCT CATEGORY CLASSIFICATION: MULTIPLE CPC
▪ primary packaging: packaging designed to come into direct contact with the product
▪ secondary packaging: packaging designed to contain one or more primary packagings together with any protective materials
where required
▪ packaging component: part of packaging that can be separated by hand or by using simple physical means
▪ packaging constituent: part from which packaging or its components are made and which cannot be separated by hand or by
using simple physical means [SOURCE: ISO 18601]
NOTE: The definition of primary packaging and secondary packaging is an aid to identify in detail the packaging solution used.
However this approach to packaging classification is not very useful for LCA studies since the product function is never identified
through these definitions. It is therefore preferable to describe the packaging through the packaging function using the definitions of
“packaging constituent” and “component” which imply the identification of the specific function performed by the packaging solution.
Here below is reported in italics the text of the PCR in chapter 2.2.2 with some application examples (in bold):
Furthermore, during the preparation of an EPD for a packaging product, the following rules shall be taken into account:
▪ In case of complex sales units, it will be possible to prepare a single EPD only in those cases where the packaging constituent
(that is, the main part of the packaging product) can be singled out. The packaging constituent performs the packaging function
and can be assembled with packaging components (other parts of the packaging product) which perform specific functions,
such as stoppers and lids. Indeed, the role of packaging components is to complete the sales unit and they are considered
auxiliary materials subject to supply. (See definitions par. 2.2.1)
EXAMPLE: A single sales unit consisting of: 500g yoghurt pot with aluminium lid (for shelf life) and polymer lid (for
refrigerated storage after opening). For this single sales unit only one EPD will be prepared in which the yogurt pot is
identified as a constituent and the two lids are auxiliaries and therefore are identified as components.
▪ In case of complex sales units (requiring, for instance, both primary and secondary packaging), several EPDs may be needed if
a number of processes are involved in the production of the various types of packaging that make up the sales unit.
EXAMPLE: A single sales unit consisting of: two yoghurt polymer pots (constituent, primary packaging) with aluminium lids
(component packaging) and printed paperboard (constituent, secondary packaging with specific closure role and packaging
protection role of the sales unit). In this case two EPDs are needed (one for each packaging constituent): one for the
primary packaging in polymer and one for the secondary packaging in printed paperboard. The aluminium lids are inserted
in the EPD of the polymer packaging as components.
▪ .In the special case of consumer packaging, where the user takes on the responsibility for packaging co-design and packaging
making in the final packaging forming and/or assembly phases, the packaging user can be equated to the packaging
manufacturer, and thus, in this case, may be an EPD Owner.
In the special case of consumer packaging, two approaches to the publication of EPDs can be envisioned: EPDs prepared by
individual manufacturers restricted to the packaging components under their responsibility, and EPDs prepared by the
packaging user, who can demonstrate its role in the core processes and prepares the EPD on the consumer packaging sales
unit.
EXAMPLE: glass bottle identifying the "brand" that binds the packaging manufacturer to the design patented by the user
company that markets the sales unit under its own responsibility (for example, by affixing its own brand). In this case, the
user's design choices affect the creation of the packaging and the related environmental performances. The design of the
product and of the production process is therefore an activity that involves the co-design collaboration between the user
and the packaging manufacturer. Both therefore can promote the publication of an EPD.
PAGE 38/39
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