Environmental Product Declarations (EPDs) have become essential documentation for manufacturers across the UAE, Saudi Arabia, and the broader GCC region. As sustainability requirements tighten in construction projects—from Dubai's green building codes to Saudi Vision 2030 initiatives—knowing how to prepare accurate product data for EPD submission can make or break your market access.

Whether you're supplying materials for LEED-certified projects in Abu Dhabi or bidding on mega infrastructure developments in Riyadh, proper data preparation ensures smoother certification and competitive advantage.

Key Takeaways

  • Data accuracy is critical: EPD submissions require precise life cycle inventory data covering raw materials, manufacturing, transport, and end-of-life stages
  • PCR compliance matters: Your data must align with relevant Product Category Rules for your industry sector
  • Documentation timeline: Proper data preparation typically takes 4-8 weeks before formal submission
  • Cost efficiency: Well-organized data reduces verification time and certification costs by up to 40%
  • Regional advantage: GCC manufacturers with verified EPDs gain preferential access to government tenders and green building projects

What Is an Environmental Product Declaration?

An Environmental Product Declaration is a standardized document that communicates the environmental impact of a product throughout its entire life cycle. Think of it as a nutrition label, but for environmental performance. Rather than listing calories and vitamins, an EPD quantifies carbon emissions, water usage, resource depletion, and other sustainability metrics.

For manufacturers in the UAE and Saudi Arabia, EPDs serve multiple purposes. They demonstrate compliance with green building standards like LEED and Estidama. They provide transparency that resonates with environmentally conscious clients. Most importantly, they're increasingly mandatory for public sector projects and private developments targeting sustainability certifications.

Why EPD Certification Matters in the GCC

The Middle East construction sector is experiencing a sustainability revolution. Dubai Municipality requires EPDs for specific material categories in high-profile projects. Saudi Arabia's Green Building Code emphasizes environmental documentation. Qatar's infrastructure development for post-World Cup legacy projects prioritizes certified sustainable materials.

Beyond regulatory compliance, EPD certification opens doors. International buyers, particularly from Europe and North America, often mandate EPDs as a prerequisite for procurement. Your competitors who obtain certification first will capture market share while others scramble to catch up.

Understanding the EPD Certification Process

Before diving into data preparation, you need to understand where your data fits in the broader EPD certification process. The journey typically follows these stages:

  1. Initial assessment and PCR selection
  2. Life cycle inventory data collection
  3. Life cycle assessment (LCA) calculation
  4. EPD document drafting
  5. Third-party verification
  6. Publication and registration

Your data preparation efforts focus primarily on stage two, but they influence every subsequent step. Poor data quality at the beginning cascades into delays, additional costs, and potential rejection during verification.

Step 1: Identify Your Product Category and Applicable PCR

Product Category Rules (PCR) define the specific requirements and calculation methodologies for your product type. These rules ensure that EPDs within the same category are comparable and follow consistent boundaries and assumptions.

Finding the Right PCR

Start by searching EPD program operator databases such as:

  • International EPD System (environdec.com)
  • UL Environment
  • BRE Global EPD scheme
  • IBU (Institut Bauen und Umwelt)

Enter your product description and review available PCRs. For example, if you manufacture cement, you'd look for PCRs covering "cement and clinker" or similar categories. Construction materials like steel, concrete, insulation, and glass typically have well-established PCRs.

If no PCR exists for your specific product, you may need to develop one—a process that adds 6-12 months to your timeline. Alternatively, consult with EPD verification bodies about using the closest applicable PCR with justified modifications.

PCR Requirements Checklist

Once you identify your PCR, review it thoroughly. Document the following requirements:

  • System boundaries: Which life cycle stages must be included (cradle-to-gate, cradle-to-grave)?
  • Functional unit: How is your product measured (per kg, per m², per unit)?
  • Data quality requirements: What level of precision is needed for different data categories?
  • Cut-off criteria: Which inputs can be excluded as negligible?
  • Allocation rules: How should environmental impacts be divided in multi-product processes?

Step 2: Gather Raw Material Data

Raw material inputs form the foundation of your EPD. This stage requires meticulous documentation of every material that enters your production process.

Primary Data Collection

Primary data comes directly from your operations. This is the most accurate and credible information for your EPD. Collect:

Material quantities: Record exact amounts of each raw material consumed per functional unit of product. For example, if producing 1 tonne of concrete, document precisely how much cement, aggregate, water, and admixtures are used.

Material specifications: Note the grade, purity, and origin of materials. Imported raw materials from Europe have different environmental profiles than locally sourced alternatives.

Transportation data: Document how materials reach your facility—distance traveled, mode of transport (truck, ship, rail), and load factors.

Secondary Data Sources

For materials you don't produce yourself, you'll need secondary data from reliable databases:

  • Ecoinvent: Comprehensive LCA database with global coverage
  • GaBi databases: Industry-specific data for chemicals, metals, and construction materials
  • ELCD (European Reference Life Cycle Database): Free resource for European data
  • USLCI (US Life Cycle Inventory): Free database for US-based data

When using secondary data, select datasets that match your material specifications as closely as possible. Geographic relevance matters—European electricity grid data differs significantly from UAE's energy mix.

Documentation Best Practices

Create a data collection spreadsheet with these columns:

  • Material name and specification
  • Quantity per functional unit
  • Unit of measurement
  • Source (primary/secondary)
  • Data quality rating
  • Geographic representativeness
  • Temporal representativeness (data year)
  • Data source reference

This structured approach simplifies verification and helps identify data gaps early.

Step 3: Document Your Manufacturing Process

Your manufacturing process generates the most significant environmental impacts and requires the most detailed data collection.

Energy Consumption

Energy use drives carbon emissions and represents a major impact category. Break down your energy consumption by:

Electricity: Monthly consumption records from utility bills provide reliable primary data. If your facility has solar panels or on-site generation, document this separately—renewable energy significantly improves your EPD profile.

Fuel usage: Record natural gas, diesel, LPG, or other fuels consumed in production. Include fuel type, quantity, and purpose (heating, transport, machinery operation).

Thermal energy: If you use steam or hot water in production, document the energy source and quantity consumed.

Water Consumption

Water usage increasingly influences sustainability ratings, especially in the water-scarce GCC region. Track:

  • Total water intake (municipal supply, groundwater, recycled water)
  • Process water consumed in production
  • Cooling water usage
  • Wastewater generation and treatment methods

Process Emissions

Direct emissions from your manufacturing process must be quantified:

  • Air emissions: VOCs, particulate matter, NOx, SOx from combustion or chemical reactions
  • Water pollutants: Discharge into municipal systems or water bodies
  • Solid waste: Production scrap, packaging waste, hazardous waste

Many manufacturers overlook fugitive emissions—unintended releases from equipment leaks, storage tanks, or handling processes. These can be significant for certain industries like chemical manufacturing or petroleum products.

Production Volume and Time Period

Document your production volume and the time period for data collection. EPD verification bodies typically require at least 12 months of production data to account for seasonal variations and ensure representativeness.

Calculate your functional unit clearly. If your PCR specifies impacts per kilogram of product, but you measure production in units or liters, establish accurate conversion factors.

Step 4: Compile Transportation and Distribution Data

Transportation impacts vary dramatically based on distance, mode, and logistics efficiency. Comprehensive transport data strengthens your EPD's accuracy.

Upstream Transportation

Raw materials must travel from suppliers to your facility. For each material input, document:

  • Origin location (city, country)
  • Distance to your facility
  • Transport mode (truck, ship, rail, air)
  • Vehicle type and load capacity
  • Load factor (percentage of vehicle capacity used)

For international shipments to GCC countries, remember to include multiple transport legs—for example, rail to port in origin country, ocean freight, and final truck delivery from Jebel Ali Port to your Dubai facility.

Internal Transportation

If your production involves multiple sites—such as raw material processing at one location and final assembly at another—document these internal logistics with the same detail as external transportation.

Distribution to Customer

Depending on your PCR's system boundary, you may need to include transportation to customers or construction sites. If required, use average distribution scenarios based on typical delivery distances and methods in your market.

Step 5: Address Packaging and Waste

Packaging materials and waste management are often underestimated components of product life cycles.

Packaging Inventory

List all packaging materials used per functional unit:

  • Primary packaging (direct contact with product)
  • Secondary packaging (boxes, pallets)
  • Tertiary packaging (stretch wrap, strapping)

Include material types (cardboard, plastic, wood), weights, and recyclability status. Returnable or reusable packaging systems offer environmental advantages—document reuse rates if applicable.

Production Waste Management

Record how production waste is managed:

  • Recycled waste: Materials sent for recycling with documented recycling rates
  • Landfilled waste: Waste sent to municipal landfills
  • Incinerated waste: Waste burned for energy recovery or disposal
  • Hazardous waste: Special waste requiring controlled disposal

If your facility operates waste-to-energy systems or internal recycling loops, document these processes thoroughly—they positively impact your EPD profile.

Step 6: Calculate End-of-Life Scenarios

Depending on PCR requirements and system boundaries, you may need to model your product's end-of-life phase. This includes product disposal, recycling potential, or reuse scenarios.

Standard End-of-Life Scenarios

For construction materials, common scenarios include:

  • Demolition and landfilling: Environmental impacts of deconstruction and transport to landfill
  • Recycling: Benefits from material recovery and substitution of virgin materials
  • Incineration with energy recovery: Impacts and credits from energy generation

Model realistic scenarios based on typical practice in your target markets. Construction waste recycling rates differ significantly between European markets (often 70-80%) and many GCC countries (typically 20-40%).

Service Life Considerations

Some PCRs require incorporating product service life—how long your product performs its intended function before replacement. Longer-lasting products distribute environmental impacts over extended periods, improving per-year performance metrics.

Step 7: Ensure Data Quality and Completeness

Data quality directly affects EPD credibility and verification success. Before submission, conduct a comprehensive data quality review.

Data Quality Assessment Criteria

Evaluate your data against these dimensions:

Temporal representativeness: Data should come from recent production periods, ideally within the past 3 years. Older data may not reflect current operations or technologies.

Geographic representativeness: Data should match the actual geographic location of processes. Using European data for a UAE manufacturing facility introduces uncertainty.

Technological representativeness: Process data should reflect your actual production technology, not generic industry averages.

Precision: Measured data is preferable to estimated data. Direct metering beats engineering calculations, which beat industry benchmarks.

Identifying and Filling Data Gaps

Create a data completeness matrix mapping every required input against available data. Common gaps include:

  • Secondary transportation distances (often assumed rather than measured)
  • Process emissions not routinely monitored
  • Packaging materials for small components
  • Ancillary material consumption (lubricants, cleaning agents)

For unavoidable gaps, use conservative estimates and document your methodology clearly. Verifiers appreciate transparency about data limitations more than unsupported assumptions.

Step 8: Organize Documentation for Verification

Third-party verification is mandatory for credible EPDs. Well-organized documentation accelerates the verification process and reduces review cycles.

Essential Documentation Package

Prepare these materials for your verifier:

  1. Data collection spreadsheet: Comprehensive inventory of all inputs and outputs
  2. Supporting records: Utility bills, purchase invoices, production records
  3. Calculation worksheets: LCA modeling files with clear methodologies
  4. PCR compliance matrix: Demonstration of how your study meets PCR requirements
  5. Data quality statements: Justification for data sources and assumptions
  6. System boundary diagram: Visual representation of included processes
  7. Process descriptions: Technical explanation of manufacturing steps

Common Verification Issues

Anticipate and address these frequent challenges:

Inconsistent units: Ensure all measurements use consistent units throughout documentation. Mixing metric and imperial units causes confusion and calculation errors.

Undocumented assumptions: Every assumption must be stated explicitly with justification. "Industry standard practice" is insufficient without citations.

Missing allocation methods: Multi-output processes require clear allocation rules. Document whether you use mass, economic value, or other allocation bases.

Insufficient precision: Verifiers need calculations to balance within 1-2%. Rounding errors or omitted decimal places cause discrepancies.

EPD vs LCA: Understanding the Relationship

Aspect Life Cycle Assessment (LCA) Environmental Product Declaration (EPD)
Purpose Analytical tool for internal decision-making Communication tool for external stakeholders
Standardization Flexible methodology (ISO 14040/14044) Highly standardized format (ISO 14025, EN 15804)
Scope Can be broad or narrow based on study goals Must follow PCR requirements exactly
Verification Optional (though recommended) Mandatory third-party verification
Public availability Usually confidential Published in public databases
Data detail Can include proprietary details Presents aggregated results only
Cost $5,000-$25,000 typically $8,000-$40,000 including LCA and verification
Timeline 2-6 months 4-10 months

Think of LCA as the analytical engine that generates environmental performance data, while EPD is the standardized report card that communicates those results to the marketplace. You cannot have an EPD without first conducting an LCA, but you can perform an LCA without publishing an EPD.

Common Mistakes to Avoid in Data Preparation

Learning from others' errors saves time and money. Watch out for these pitfalls:

Mistake 1: Starting Data Collection Too Late

Many manufacturers begin gathering data only after deciding to pursue EPD certification. This reactive approach causes problems. Production records may be incomplete, key personnel may have left, and operational changes make historical data less relevant.

Solution: Implement continuous environmental data tracking as standard practice, even before pursuing EPD certification. Modern manufacturing systems can automate much of this data capture.

Mistake 2: Neglecting Indirect Inputs

Focus often concentrates on major raw materials while overlooking smaller inputs—lubricants, cleaning chemicals, maintenance materials, office supplies. While individually minor, collectively these can represent 5-10% of total impacts.

Solution: Review all procurement categories, not just primary production materials. If an input appears in your accounting system, evaluate whether it should appear in your EPD data.

Mistake 3: Using Inappropriate Secondary Data

Substituting generic database values when specific data is available, or using geographically distant data when local alternatives exist, undermines EPD accuracy.

Solution: Prioritize data specificity. Use supplier-specific EPDs when available. Select database entries matching your geographic region and technological context.

Mistake 4: Ignoring Co-Product Allocation

Many manufacturing processes generate multiple products or valuable by-products. Failing to allocate environmental impacts properly among co-products violates PCR requirements and distorts results.

Solution: Consult your PCR for prescribed allocation methods. Document allocation calculations explicitly and consider sensitivity analysis to evaluate how allocation choices affect results.

Mistake 5: Poor Version Control

EPD preparation involves multiple calculation iterations as data is refined and verifier feedback is incorporated. Without proper version control, it's easy to lose track of changes or submit outdated information.

Solution: Implement formal document version control. Date and number every calculation file. Maintain a change log documenting what was modified and why.

Tools and Software for EPD Data Management

Appropriate tools streamline data collection, calculation, and documentation. Your needs depend on complexity, budget, and internal expertise.

LCA Software Platforms

Professional LCA software is essential for EPD development:

GaBi: Comprehensive platform with extensive material databases and GCC-relevant data. Widely used in construction and chemical industries. Higher cost but powerful features. (Contact for pricing, typically $10,000-$30,000 annually)

SimaPro: Popular alternative with intuitive interface. Strong integration with Ecoinvent database. Good for first-time users. (Starting around $8,000 annually)

OpenLCA: Free, open-source option suitable for budget-conscious users. Steeper learning curve but no licensing costs.

Data Collection Templates

Several organizations offer free EPD data collection templates:

  • Pre.org (formerly PRé Sustainability) provides industry-specific templates
  • EPD International offers PCR-aligned data collection worksheets
  • UL Environment provides guidance documents with data tables

Digital EPD Platforms

Emerging digital platforms simplify EPD creation:

One Click LCA: Cloud-based tool popular in construction. Includes material databases tailored to GCC region. Pricing varies by subscription tier.

Sphera Solutions: Enterprise-level sustainability software integrating EPD management with broader environmental reporting.

ECO Platform: Collaborative platform for construction materials, particularly relevant for North American markets.

EPD Certification Cost and Timeline in the GCC

Understanding the investment required helps with budgeting and planning.

Cost Breakdown

Total EPD certification costs typically include:

  • LCA modeling: $5,000-$15,000 depending on product complexity
  • Third-party verification: $3,000-$10,000 based on verifier and product type
  • Program registration: $500-$2,000 for EPD publication and database registration
  • Consultant fees (if outsourced): $8,000-$25,000 for full-service EPD development
  • Software licenses: $8,000-$30,000 annually if purchasing LCA software

Total investment: $15,000-$40,000 for first. Subsequent EPDs for similar products cost 30-50% less by leveraging existing data and processes.

For SMEs in the UAE and Saudi Arabia, this represents a significant investment. However, government grants and sustainability incentives sometimes offset costs. Check with entities like Dubai SME, Saudi Industrial Development Fund, or local chambers of commerce.

Timeline Expectations

Realistic timeframes for EPD completion:

  • Data collection: 4-8 weeks
  • LCA modeling and calculation: 3-6 weeks
  • EPD document preparation: 2-3 weeks
  • Third-party verification: 4-8 weeks (including review cycles)
  • Publication and registration: 1-2 weeks

Total timeline: 4-6 months from project initiation to published EPD.

Accelerated timelines are possible with dedicated resources and prior preparation. Well-organized manufacturers with robust data systems can complete the process in 3 months. Conversely, complex products or data quality issues can extend the timeline beyond 6 months.

How SMEs Can Reduce EPD Costs

Small and medium enterprises face budget constraints but can still achieve EPD certification through strategic approaches.

Industry Collaboration

Sector-wide EPDs: Multiple manufacturers producing similar products can share costs by developing a collective industry-average EPD. Trade associations in the GCC sometimes coordinate these initiatives. While individual EPDs are preferable for marketing differentiation, sector EPDs provide market access at lower cost.

Phased Approach

Rather than certifying your entire product portfolio simultaneously, prioritize:

  1. Products required for immediate tenders or projects
  2. High-volume products with greatest market impact
  3. Products where EPD provides strongest competitive advantage

Develop internal capability through the first EPD, then expand to additional products using lessons learned and established processes.

Government Support Programs

Research available sustainability incentives:

  • Dubai Carbon Centre of Excellence offers advisory services
  • Saudi Energy Efficiency Center provides technical assistance
  • Some free zones offer sustainability certification support for tenants

Training Investment

Instead of fully outsourcing EPD development, train internal staff on LCA methodology and EPD preparation. Initial consultant engagement for first EPD combined with knowledge transfer can build long-term capability at lower total cost.

Consider sending team members to certification courses like:

  • Life Cycle Assessment Practitioner Training
  • ISO 14040/14044 Courses
  • EPD-specific workshops offered by program operators

Regional Requirements: UAE and Saudi Arabia

While EPD standards are international, regional nuances affect implementation.

UAE-Specific Considerations

Dubai Municipality Green Building Regulations: Specify EPD requirements for certain material categories in government projects. Al Sa'fat Green Building System awards points for EPD-certified materials.

Estidama (Abu Dhabi): Pearl Building Rating System credits EPD submission. Projects targeting 2 Pearls or higher increasingly require EPDs for major material categories.

LEED Projects: UAE has one of the world's highest concentrations of LEED-certified buildings. EPDs contribute to Materials & Resources credits, making them valuable for suppliers to these projects.

Saudi Arabia-Specific Considerations

Vision 2030 Projects: Mega-developments like NEOM, Red Sea Project, and Qiddiya prioritize sustainability. EPDs feature prominently in material procurement specifications.

Saudi Building Code: Energy efficiency requirements increasingly reference environmental documentation including EPDs.

MODON Industrial Cities: Some facilities offer support for tenant sustainability initiatives, potentially including EPD development assistance.

Export Considerations

If exporting to Europe or North America, recognize that:

  • Different EPD program operators dominate different markets
  • Product Category Rules may vary between regions
  • Additional certifications (like European CE marking) may be required alongside EPDs

Future-Proofing Your EPD Investment

EPDs require periodic renewal (typically every 5 years). Design your data systems for long-term sustainability.

Continuous Data Collection

Rather than scrambling for data every 5 years, implement ongoing environmental data tracking:

  • Automate utility data capture from smart meters
  • Integrate material consumption tracking with inventory management systems
  • Establish quarterly environmental reporting alongside financial reporting

This approach reduces EPD update costs and provides valuable insights for continuous improvement.

Digital Records Management

Maintain comprehensive digital archives of:

  • All EPD-related documentation and calculations
  • Production process descriptions and flowcharts
  • Contact information for verifiers and program operators
  • Change logs for production processes or material inputs

Cloud-based document management ensures accessibility and prevents data loss.

Process Optimization

Use EPD data to identify environmental hotspots in your operations. Even modest improvements in energy efficiency or waste reduction enhance your next EPD update while delivering immediate cost savings.

Many manufacturers discover that EPD development process reveals opportunities for operational improvements that quickly offset certification costs.

Frequently Asked Questions

Q: How long does data collection for EPD submission typically take?

A: For manufacturers with organized production records, data collection takes 4-8 weeks. Companies without environmental tracking systems may need 10-12 weeks to gather historical data and fill gaps. The key is starting with a comprehensive data requirements checklist based on your PCR.

Q: Can I use estimated data instead of measured data for my EPD?

A: PCRs generally require measured primary data for significant processes and inputs. Estimates are acceptable only for minor contributors (typically those representing less than 5% of total impacts). However, all estimates must be conservative and clearly documented with supporting rationale for verification.

Q: What's the minimum production history required for EPD certification?

A: Most EPD programs require at least 12 months of production data to ensure representativeness and account for seasonal variations. Newer products with less than one year of production history may still qualify, but require documented justification and may face additional scrutiny during verification.

Q: How specific should transportation data be?

A: Transport data should reflect actual logistics as accurately as possible. Document origin and destination locations, distance (using mapping tools if needed), transport mode, and vehicle type. For recurring shipments, average data over the collection period is acceptable. Avoid generic assumptions like "500 km by truck" without supporting evidence.

Q: Do I need separate EPDs for different product variants?

A: This depends on how significantly variants differ. Minor variations (colors, sizes within the same manufacturing process) typically don't require separate EPDs. Significant differences in composition, production process, or performance characteristics generally require separate EPDs. Consult your PCR and verification body for guidance on your specific situation.

Q: What happens if my production process changes after EPD publication?

A: Minor changes (less than 10% variation in key impact indicators) can usually wait until your scheduled EPD update (typically 5 years). Significant process modifications—new equipment, different raw materials, facility relocation—require EPD re-calculation and re-verification. Document all production changes to evaluate whether EPD updates are necessary.

Q: Can I prepare EPD data internally without hiring consultants?

A: Yes, with appropriate training and software tools. Many medium to large manufacturers successfully develop EPDs in-house. However, the learning curve is significant for first-time users. A hybrid approach—consultant support for the first EPD with knowledge transfer—often provides the best balance of quality, capability building, and cost-effectiveness.

Q: How do I choose between different EPD program operators?

A: Consider market acceptance in your target regions. International EPD System has broad global recognition. UL Environment is strong in North American markets. BRE dominates UK construction. Choose based on where your products are sold and what your customers recognize. Some manufacturers obtain EPDs from multiple programs to maximize market coverage.

Conclusion

Preparing product data for EPD submission requires systematic organization, attention to detail, and commitment to accuracy. The investment in comprehensive data collection pays dividends through smoother verification, lower costs, and stronger market positioning.

For GCC manufacturers, EPD certification is transitioning from competitive advantage to market necessity. Government projects increasingly mandate EPDs. International buyers expect them. Green building standards reward them. Starting your data preparation journey today positions your company for tomorrow's requirements.

Remember that EPD development is not just a compliance exercise—it's an opportunity to deeply understand your product's environmental footprint, identify improvement opportunities, and communicate your sustainability commitment to the marketplace.

Ready to begin your EPD journey? Start by reviewing available Product Category Rules for your products and conducting a preliminary data inventory assessment. The sooner you establish robust environmental data collection systems, the easier and more cost-effective your EPD certification process will be.

What environmental story does your product data tell? The answer might surprise you—and could become your strongest competitive advantage.

Glossary

Cradle-to-gate: System boundary including all processes from raw material extraction through factory gate, excluding distribution and end-of-life

Cradle-to-grave: Complete life cycle from raw material extraction through product use and final disposal

Cut-off criteria: Threshold below which inputs can be excluded from analysis (typically 1-5% of mass or environmental impact)

Ecoinvent: Comprehensive life cycle inventory database widely used as secondary data source for LCA studies

Functional unit: Quantified performance measure serving as reference basis for EPD (e.g., 1 m² of insulation with R-value 3.5)

Life Cycle Assessment (LCA): Methodology for evaluating environmental impacts throughout product life cycle per ISO 14040/14044

Life Cycle Inventory (LCI): Data collection phase of LCA documenting all inputs and outputs for each process

PCR (Product Category Rules): Set of specific rules, requirements, and guidelines for developing EPDs in a specific product category

Primary data: Information collected directly from your operations through measurement or monitoring

Secondary data: Generic data from databases, literature, or industry averages representing processes outside your control

System boundary: Definition of which processes are included in or excluded from the LCA study

Third-party verification: Independent review by qualified verifier confirming EPD complies with standards and PCR requirements