Growing the market for low carbon industrial products: policy framework - Chapter 3: Guidance in the Embodied Emissions Reporting Framework - Department for Energy Security and Net Zero

3.1. Which option for the reporting metric do you think the guidance should recommend? Please explain your reasoning, and details of any alternative options.

Option 1: Declared unit, regardless of whether the final use of the product is known by the producer Option 2: Functional unit, where possible if the function of the product is known to the producer and the use of a declared unit where that is not feasible Option 3: The producer should record the metric they consider most appropriate Option 4: Other (please specify)

3.2. Which part of the product’s life cycle should the EERF guidance recommend reporting on? Please explain your reasoning.

Option 1: Aligned with EN 15804 (as per the scenarios above) Option 2: A1-A3 as a minimum requirement and any reporting of other modules at the producer’s discretion Option 3: Other (please specify)

3.3. For steel producers, which of the options for reporting standards should the EERF guidance endorse? Please explain your reasoning.

Option 1: A general product standard (such as ISO 14067, Greenhouse Gas Protocol for Products, or PAS 2050). (If so, please specify) Option 2: ISO 14025 with the appropriate PCR (if so, please define the level of product standard specificity desired: for example BS EN 15804 only) Option 3: Industry specific standard (such as ISO 20915). (If so, please specify) Option 4: Product classification(s) only (please specify) Option 5: Other (please specify)

Please explain your reasoning

3.4. For cement and concrete producers which of the options for reporting standards should the EERF guidance endorse? Please explain your reasoning.

Option 1: A general product standard (such as ISO 14067, Greenhouse Gas Protocol for Products, or PAS 2050). (If so, please specify) Option 2: ISO 14025 with the appropriate PCR (if so, please define the level of product standard specificity desired: for example EN 15804 only) Option 3: Industry specific standard (If so, please specify) Option 4: Product classification(s) only (please specify) Option 5: Other (please specify)

3.6. If you believe that there are issues with the EPD verification process, which of the below possible issues apply? Please explain your reasoning. [select all that apply]

Option 1: Robustness of verification process Option 2: Verification time following submission of EPD Option 3: Cost of EPD verification Option 4: Comparability of results Option 5: Availability of qualified verifiers Option 6: Other (please specify) Option 7: None of the above

3.7. Do you believe that any of the following possible government interventions could help improve the robustness and quality of the current EPD verification process and capacity in the market? Please explain your reasoning. [select all that apply]

Option 1: Produce guidance Option 2: Support the creation of verification tools Option 3: Work with or accredit programme operators Option 4: Select or establish a particular programme operator Option 5: No intervention Option 6: Other (please specify)

3.8. Which options should the EERF guidance recommend regarding secondary data? Please explain your reasoning.

Option 1: Secondary data from a single database Option 2: No specific policy on secondary data other than what is specified in standards Option 3: Other (please specify)

3.9. If you answered Option 1 to Question 3.8, which secondary database do you think reporting should be in accordance with for cement and concrete? Please explain your reasoning.

Option 1: ICE Option 2: Ecoinvent Option 3: Sphera (formerly known as GaBi) Option 4: Other (please specify)

3.10. If you answered Option 1 to Question 3.8, which secondary database do you think reporting should be in accordance with for steel? Please explain your reasoning.

Option 1: ICE Option 2: Ecoinvent Option 3: Sphera (formerly known as GaBi) Option 4: Other (please specify)

3.11. Separate to the specific rules of product classifications, do you consider that the EERF guidance should specify a particular allocation of co-products method and if so what method? Please explain your reasoning.

Option 1: No specific policy on allocation Option 2: No allocation Option 3: Economic allocation Option 4: Physical partitioning Option 5: System expansion Option 6: Mass-based allocation Option 7: Other (please specify)

3.12. Do you agree or disagree with the proposal that both net and gross emissions figures from production should be reported in the EERF guidance? Please explain your reasoning.

3.13. Do you agree or disagree with this proposal to use gross emissions (which include emissions from non-biogenic waste) when a single emissions figure is required? Please explain your reasoning.

3.14. Do you agree or disagree with the proposed guidance recommending reporting the embodied emissions of products in accordance with BS EN 15941? Please explain your reasoning.

Please explain your reasoning

3.15. Considering the objectives of this section and the proposed emissions reporting guidance, are there any other methodological areas where respondents think there needs to be a consistent or coordinated approach, or other considerations that the government should be aware of?