California Air Resources Board

As the manufacturer who introduced EPDs to the US market, Interface has had a unique role in promoting Embodied Carbon as a key metric for building products. We have been working with ACLCA and Building Transparency (our staff has Chaired the Board for both organizations) for years to improve data quality and accessibility. See the attached for a current survey of GWP/Embodied Carbon numbers for products in US-made carpet tile. The main comment we would like to submit is a concern for a major loophole emerging in LCA practice in the US that is being closed by EU program operators for EPDs: free allocation mass balancing. In carpet tile, the data is being skewed by vertically integrated mills who make their own nylon yarn and allocate all of their post-industrial waste that is reused within their process to specific EPDs and claim products are made with "100% recycled content nylon" even though their nylon production system uses a much lower percentage of recycled materials on an annualized basis. Because nylon production from crude oil accounts for at least 50% of the GWP of any carpet product, and recycled nylon data sets do not distinguish pre- from post-consumer recycled materials, this results in the appearance of much lower GWP products with little to no change in industrial emissions from the nylon production system, only a reallocation of those emissions away from "low-carbon" products and yarn systems (e.g., Shaw's EcoSolution Q100). This kind of accounting has the potential of decouple GWP reductions from actual industrial innovation and decarbonization and we recommend CARB adopt best practices from the ACLCA for the appropriate use of mass balancing in LCA models.