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Commenting form for "ACLCA Guidance and Guardrails for Accounting Mass Balance Chain-of-Custody Approaches in Life Cycle Assessments (LCAs) and Environmental Product Declarations (EPDs) - Working Draft Version 3 - Public Consultation"
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ACLCA is seeking public comment on its draft Guidance and Guardrails for Accounting Mass Balance Chain-of-Custody Approaches in Life Cycle Assessments (LCAs) and Environmental Product Declarations (EPDs).The public comment period runs 60 calendar days and closes on Monday, December 7, 2026.
To submit comments, please use one of the following: ---- Add them directly to the comment spreadsheet ------ Complete the attached comment template and submit via email to gskoglund@aclca.org
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‍Commenter nameDate of commentSectionLine #Nature of comment (editorial, general, technical)CommentProposed change
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Joe Bob Smith 10/06/262.358editorialThe acronym EPD is misspelled as EDPCorrect spelling to EPD
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‍John Schweitzer10/9/20262.5540generalWhy require 3rd party verification for input accounting when MB is used but not otherwise? A product manufacturer can always use a different raw material source than was identified during preparation of the LCA. For example, an input material produced using renewable energy could be specified for the LCA, but material from a different source actually used to make the product. If we are concerned about the product manufacturer using incorrect input accounting, then the accounting for all production inputs would need to be verified, not just for inputs containing recycled content. There are significant sources of potential error in LCA, MB accounting is only one of them. 3rd-party verification is likely to be expensive enough that this requirement would prevent smaller companies from using MB accounting.Do not require 3rd party verification.
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Vito D'Incognito (VDI)2/11/2026Abstract47editorialthe NIST study is not referenced.add the reference year on the line 47 and the full title of the NIST study in the reference list
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Vito D'Incognito (VDI)2/11/2026Abstract78editorialGiven the pros and cons, the... define the meaning of pros and cons, or add in the llist of acronyms and abbreviations
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4Vito D'Incognito (VDI)1.1149-150technicalit is completely missed the European RED directive that contains also technical ruels and requirements for the mass balance principles, application and verification in the area of the biofuels.cite the RED directive and also the biofuels section for its relevance
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51.3304technicalMB-CM has also been applied to overcome the limitations of mass and economic allocation in LCA of carbon dioxide removal systems while following ISO 14040 and 14044. the carbon dioxide removal is not allowed from the ISO 14040-44 or ISO 14067 standards.please delet the sentence nd the reference.
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6allocation in LCA of carbon dioxide removal systems
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