Data selection has always been a central issue in life cycle assessment, but its regulatory importance is increasing rapidly. As LCAs move from internal decision-support tools to instruments of compliance and market access, regulators and verifiers are placing greater emphasis on the use of primary, facility-specific data. While secondary datasets remain an essential component of many LCAs, reliance on generic data is increasingly viewed as a limitation rather than a convenience.
ISO 14040 and ISO 14044 allow the use of secondary data where primary data is unavailable or impractical to obtain, provided data quality requirements are met. However, these standards also emphasize representativeness, transparency, and fitness for purpose. In regulated contexts, these principles are being interpreted more strictly, particularly where emissions values have financial or compliance implications.
Regulatory programs such as the EU Renewable Energy Directive and the California Low Carbon Fuel Standard increasingly expect that key parameters influencing lifecycle emissions are based on measured operational data. Energy consumption, feedstock composition, yields, and process efficiencies are areas where regulators and verifiers prefer primary data. LCAs that rely on default or industry-average values in these areas are more likely to be challenged during review.
The same trend is emerging in product carbon footprinting under ISO 14067. Customers and regulators alike are increasingly skeptical of product-level emissions data derived predominantly from secondary datasets. While background processes may reasonably rely on established databases, foreground processes are expected to reflect actual operations. Failure to make this distinction can undermine confidence in reported results.
Secondary data also presents challenges related to consistency and transparency. Databases may apply assumptions or modeling approaches that differ from regulatory methodologies. Geographic and temporal mismatches can further reduce relevance, particularly in rapidly evolving energy systems. When such data is used without sufficient documentation or justification, it can weaken an LCA’s defensibility.
The shift toward primary data has practical implications. Collecting, managing, and validating facility-specific data requires robust internal controls and coordination across operational teams. It also increases the importance of testing, inspection, and metering systems that provide reliable inputs to LCA models. As regulatory scrutiny increases, data governance becomes as important as methodological rigor.
Importantly, the move toward primary data does not eliminate the role of secondary datasets. Rather, it changes how they are used. High-quality secondary data remains essential for upstream processes that are beyond the direct control of the reporting entity. The key regulatory expectation is that the balance between primary and secondary data is appropriate for the intended application and is transparently documented.
As LCAs become embedded in compliance frameworks, organizations that continue to rely heavily on generic data may find themselves at a disadvantage. LCAs grounded in primary, verifiable data are more likely to withstand regulatory review and support credible sustainability claims.
AmSpec’s Business Assurance & Sustainability division supports clients in developing LCAs that integrate primary operational data with appropriate secondary datasets. Through testing, inspection, and independent assurance, AmSpec helps ensure that LCA inputs meet evolving regulatory and verification expectations.