May I register an EPD for a product without 1-year production data?

In general, LCI data shall be based on data from at least 1 year of production. If such data is not available because the product has not yet been produced for 1 year, the LCI data may be based on data from a shorter time period (e.g., 3 months) provided that the data can be proved to be conservative or representative for 1-year data, accounting for effects of seasonal variations and incidences influencing productivity (e.g., manufacturing downtime due to equipment failure or maintenance). In such cases, the product description shall include a disclaimer, and the EPD shall be updated and re-verified when data from 1 year of production is available. See Section 9.5 in the General Programme Instructions (GPI) for more rules on such EPDs, including specifics on the disclaimer to include. Old PCRs may have deviating rules, but its recommended to follow version 5.0.0 of the GPI unless its rules violates any requirements in the applicable PCR.