Our comment/proposal is related to "MR Prerequisite: Assess Embodied Carbon", "MR Credit: Reduce Embodied Carbon" and "Optimized Building Products".

GWP benchmark values other than GSA IRA limits should be allowed for projects outside the U.S. for the right assessments. Each of the GSA IRA limits was developed based on a PCR (Product Category Rule) intended primarily for EPDs in the U.S. market. EPDs based on such PCR have limited validity and comparability when used outside the US.

Under LEED, which is the global green building certification system, regional values should be used as benchmarks when appropriate values are available. The regional benchmark outside the U.S. could be an industry-wide EPD (sector EPD) issued by an EPD program in the country, or it could be an average based on existing EPDs available in the country, which is calculated by a legitimate EPD program operator in the country. If valid/enough EPDs are not available in the market, the GSA IRA limits should be used to avoid allowing unreliable/unfair benchmarks.

In addition, as for tier 2 and 3 values, there may be only one industry-wide EPD available in the market, and it could be challenging to set appropriate values for "top 20%" and "top 40%". In such case, Tier 2 could be "more than 10% reduction" and Tier 3 could be "more than 20% reduction" compared to the regional benchmark.