The aluminum industry is challenging a new window Product Category Rule (PCR) developed by the Institute for Environmental Research and Education (IERE).

PCRs are the guidelines used to create comparable Environmental Product Declarations (EPDs) among products that serve similar functions. An EPD could be considered a “nutrition label” for a products’ Life Cycle Analysis (LCA).

Members of the aluminum industry say they are concerned with the IERE’s new window PCR, which has been developed on behalf of several glass and window industry associations (the full list of committee members are listed on page 3 of the review), because it utilizes a “Cradle-to-Gate” methodology in determining products’ footprint at the end of life as opposed to a “Cradle-to-Grave” one.

“In this method [used in the PCR] … the burden of recycling belongs to the next life cycle, whether that life cycle is in the same industry or another one,” explains IERE executive director Rita Schenck, chair of the PRC’s committee. “If a recycled material is used in a product, the burden of recycling is accounted for in that product life cycle.”

The aluminum extrusion industry believes that method, however, doesn’t accurately depict aluminum’s true life cycle and therefore puts it as a disadvantage when up against other materials in the LCA sphere.

“Their argument is that they already credit the recycled content within the component,” says Guy Charpentier, marketing manager at Bonnell Aluminum. “…But again, it’s not taking into account the total life cycle of the product. Basically, they claim that the end of life stops at the demolition stage, and we’re saying that’s not true.”

Charpentier explains that most metals—particularly, but not limited to, aluminum in demolition situations—are being regularly recycled.

He cites a 2012 study by the Aluminum Association—the organization leading the way in the push-back regarding the new PCR—which, during a recent building demolition investigation sponsored by the association, showed a 98 percent recycle rate of aluminum recovered at a randomly selected site in Seattle.

The aluminum industry contends that’s a more accurate depiction of aluminum’s high rate of recyclability, disputing Schenck’s claim in an email sent to industry members that “only 17 percent of the aluminum sold in the U.S. in 2013 was from post-consumer scrap.”

“To pigeonhole it at 17 percent doesn’t reflect reality,” says Jeff Henderson, director of operations at the Aluminum Extruders Council (AEC).

The AEC sent out a “Call to Action” letter to its constituents at the beginning of July to drum up support for the Aluminum Association’s pushback on the matter.

“The president of the Aluminum Association went out with a statement, basically that any PCR that doesn’t acknowledge recycled content in materials use should be questioned,” Henderson said. “… We took that information to our membership, and I must tell you, the extruders came out in full force.”

Adds Lewie Smith, president of Jordan Aluminum Company, “I think as these building LCA requirements become more and more important, we will see the effect over the next few years. I don’t think it will affect things tomorrow… but everyone recognizes these are important issues as LCAs are becoming a bigger part of the building industry, and our industry needs to jump ahead of this curve.”

While acknowledging the aluminum industry’s concerns and recognizing their reasoning, Schenck assures that “there is no intent in the General Program Instructions to bias against any material, merely to model the systems as close to reality as possible.”

“Fundamentally, the approach we have taken is not different for aluminum—we have treated it exactly the same as all other materials,” she adds. “Part of the difference is that the aluminum industry is calculating the impact of an average ton of aluminum, while an EPD is supposed to calculate the impacts of a certain article, in this case a window.”

The PRC draft can be viewed in full here.