PCS TR 011 Tire Devulcanization Methodology_v1.0
Document Control
Document identification
**Document code:**PCS-TR-011
Title: Tire Devulcanization Methodology
Scope: Defines eligibility conditions, boundary and baseline determination rules, additionality requirements, monitoring requirements, leakage treatment, and calculation procedures for PCS projects that process end-of-life tires through devulcanization to produce reclaimed rubber that displaces virgin rubber or other baseline rubber inputs, and that avoid baseline end-of-life management pathways, resulting in measurable and verifiable net GHG emission reductions.
Version history and change log
Table DC-1. Revision history
v1.0
TBD
Draft
Release for public consultation
PCS
TBD
Superseded versions
No superseded versions for v1.0.
Governance note on versioning and archiving
Only the latest approved version of this Methodology shall be used. Superseded versions shall be archived and retained for traceability and audit purposes. Printed or downloaded copies are uncontrolled; stakeholders must refer to the PCS-published version as the authoritative current version.
Chapter 1 - Purpose
1.1 Purpose
This methodology establishes activity-specific requirements for quantifying emission reductions from projects that process end-of-life tires through devulcanization to produce reclaimed rubber materials that substitute for baseline rubber inputs, while ensuring that the baseline end-of-life tire management pathways and project supply chains are treated conservatively under the Planetary Carbon Standard (PCS).
The methodology sets rules for eligibility, baseline scenario identification, system boundary definition, monitoring and calculation procedures, and conservative leakage treatment to ensure that credited reductions reflect real, additional, and verifiable net climate benefits.
1.2 Intended use
This methodology shall be applied to projects that receive and process end-of-life tires and produce devulcanized rubber output that is sold or transferred for use as an input material in defined downstream applications. The project shall demonstrate that the reclaimed rubber output results in substitution of baseline materials and that substitution is not double counted under another crediting program or compliance instrument.
The project proponent shall quantify emission reductions using monitored and verifiable data. Where direct measurement is not feasible for certain parameters, conservative approaches may be applied only where allowed under this methodology and where environmental integrity is protected through conservative assumptions and verification controls.
1.3 Relationship to other PCS documents
This methodology shall be applied together with applicable PCS standards, any PCS methodological tools referenced by this methodology, and the approved PCS templates and forms used for project submission and monitoring/reporting. In the event of inconsistency, higher-order PCS documents prevail.
1.4 Binding nature
Requirements expressed using “shall” are mandatory. Where this methodology references a methodological tool, that tool shall be applied as specified. PCS templates and forms required for submissions shall be used without substitution unless an explicit exception is granted through the PCS deviation process.
1.5 Version control and applicability
This methodology is subject to controlled versioning. The applicable version is the version in force at the time of project submission unless transition provisions specify otherwise. Revisions do not apply until they enter into force under PCS governance procedures.
Chapter 2 - Scope and Applicability
2.1 Scope
This methodology applies to projects that reduce GHG emissions by processing end-of-life tires through devulcanization and delivering reclaimed rubber output that substitutes for baseline rubber inputs and/or baseline rubber-containing materials in defined product systems.
The methodology is designed for situations where the project can demonstrate traceable sourcing of end-of-life tires, measurable and auditable processing outputs, credible identification of baseline end-of-life management pathways for tires, and credible evidence of substitution of baseline materials by the devulcanized rubber output.
2.2 Eligible project types
Eligible project types include facilities that implement mechanical, thermal, chemical, or hybrid devulcanization processes that reclaim rubber from end-of-life tires and produce a defined reclaimed rubber output stream intended for use as a material input.
Projects may include pre-processing such as shredding, granulation, and separation where these are integral to the devulcanization process and are within the project boundary as defined in Chapter 4.
Projects that primarily produce tire-derived fuel, use tires primarily as a combustion fuel, or claim reductions primarily from energy recovery rather than material substitution are not eligible under this methodology.
2.3 Eligible feedstock
Eligible feedstock shall consist of end-of-life tires that would otherwise be managed through baseline end-of-life pathways in the absence of the project.
The project shall define the geographic sourcing area and demonstrate that the collected tires are not already obligated to be processed by a legally binding requirement that would result in equivalent devulcanization or equivalent material recycling absent the project.
The project shall demonstrate that feedstock is not diverted from another material recycling pathway that is already delivering equivalent substitution benefits and is already credited or claimed elsewhere, unless non-overlap and conservative treatment are demonstrated.
2.4 Eligible products and substitution basis
Crediting under this methodology is based on substitution. The project shall define the reclaimed rubber output specification and the eligible downstream applications for which substitution claims are made.
The project shall demonstrate functional equivalence between the project reclaimed rubber used and the baseline input it replaces, expressed on a defined functional unit basis. Where functional equivalence is partial due to quality, performance, or formulation constraints, the project shall apply conservative substitution ratios and shall not assume one-to-one substitution.
The project shall not claim substitution benefits for stockpiled output, unsold output, or output used in applications where substitution cannot be evidenced.
2.5 Exclusions and non-applicable cases
This methodology shall not be applied where baseline end-of-life tire management cannot be credibly established, where project feedstock traceability is not auditable, where product substitution cannot be evidenced, where the project relies on speculative market transformation claims, or where double counting risks cannot be managed.
Projects that involve illegal dumping, uncontrolled open burning, or other non-compliant baseline scenarios shall treat baseline conservatively and shall not claim benefits from correcting illegal practices unless PCS requirements allow and the baseline is evidenced and conservative.
Projects that are legally mandated or required by enforceable permit conditions to undertake devulcanization for the relevant waste stream are not eligible.
2.6 Applicability conditions
A project shall be applicable under this methodology only where it can define and evidence the following elements in a manner suitable for validation and verification.
The project shall define the devulcanization process boundary and demonstrate that inputs, outputs, and energy consumption can be monitored and audited. The project shall establish a credible baseline scenario that includes both the baseline end-of-life management of the tires and the baseline production of the substituted material(s). The project shall provide evidence of downstream use and substitution for credited output quantities. The project shall quantify project emissions from processing and energy use and apply leakage deductions where required.
Chapter 3 - Conditions for Eligibility
3.1 General eligibility requirement
A project shall be eligible under this methodology only where it is demonstrably within scope, meets all applicability conditions, and can be validated and verified using auditable records. A project shall not proceed to registration where the methodology is not fully applicable or where required evidence cannot be produced in a verifiable form.
3.2 Project activity eligibility
The project activity shall consist of processing eligible end-of-life tires through a defined devulcanization process to produce a reclaimed rubber output that is used as a material input in downstream applications and that results in substitution of baseline rubber inputs.
The project shall define the process configuration, including pre-processing steps that are integral to devulcanization, the reclaimed rubber output stream(s), and the quality specifications relevant to downstream use. The project shall demonstrate that the primary value pathway is material substitution and not combustion for energy recovery.
Where the facility produces multiple output streams, the project shall define which output stream(s) are eligible for crediting and shall ensure that substitution claims are made only for those eligible outputs that are sold or transferred for use in defined substitution applications.
3.3 Feedstock eligibility and legal compliance
Feedstock shall consist of end-of-life tires sourced in accordance with applicable law and regulation. The project proponent shall demonstrate that tires are collected, transported, stored, and processed in compliance with relevant waste management, hazardous materials, occupational safety, and environmental permitting requirements.
The project shall not credit feedstock that is unlawfully collected, unlawfully transported, or otherwise associated with non-compliant waste handling. If the project receives mixed or uncertain feedstock, the project shall segregate eligible quantities through auditable controls. Where segregation cannot be demonstrated, conservative treatment shall be applied, including excluding affected quantities from crediting.
3.4 Feedstock additionality and diversion control
The project shall demonstrate that eligible feedstock would not have been devulcanized or otherwise materially recycled into equivalent reclaimed rubber outputs in the absence of the project.
The project shall assess diversion risks. Where tires are diverted from existing material recycling pathways that already result in equivalent substitution benefits, the project shall demonstrate non-overlap and ensure that net benefits are not double counted. Where diversion cannot be credibly excluded or conservatively quantified, the affected quantities shall be deemed ineligible.
Where extended producer responsibility schemes, take-back obligations, or legally binding recycling targets exist, the project shall demonstrate that credited reductions are not simply compliance with legally mandated recycling outcomes and that the project remains additional under PCS requirements.
3.5 Baseline end-of-life tire management credibility
The project shall identify and justify the baseline end-of-life management pathway(s) for the tires collected. The baseline pathway shall be evidence-based and representative of the sourcing geography and market conditions.
The baseline shall not be defined as an extreme or atypical disposal pathway unless it is demonstrably representative. Where baseline pathways vary across the sourcing area, the project shall treat baseline conservatively and shall disaggregate pathways where required to avoid over-crediting.
Where illegal dumping, uncontrolled open burning, or other non-compliant practices exist in the region, the project shall not automatically assume such practices as baseline. If such practices are asserted as baseline, the project shall provide credible evidence of prevalence and shall apply conservative treatment consistent with PCS requirements.
3.6 Substitution eligibility and functional equivalence
Crediting under this methodology is based on substitution. The project shall demonstrate that reclaimed rubber output is used to substitute baseline rubber inputs in eligible downstream applications.
The project shall define the functional unit used for substitution claims and demonstrate that project output and baseline input are comparable for the intended use. Where the project output cannot fully substitute baseline material on a one-to-one basis due to quality, performance, formulation limits, or blending constraints, the project shall apply conservative substitution ratios supported by evidence.
The project shall not claim substitution where reclaimed rubber is stockpiled, disposed, used for energy recovery, or used in applications where displacement of baseline rubber inputs cannot be evidenced.
3.7 Evidence of downstream use and prevention of double claiming
The project shall demonstrate downstream use through auditable evidence. Evidence shall link eligible quantities of reclaimed rubber output to specific buyers, applications, and periods.
The project shall address double claiming risk. Where the buyer, manufacturer, or downstream program also claims recycled content benefits, emissions reductions, or other environmental attributes for the same material, the project proponent shall demonstrate that PCS crediting does not overlap with those claims, or shall apply conservative treatment that prevents double counting.
Where the project output is sold into intermediary markets, the project shall implement traceability controls sufficient to demonstrate eligible use or shall apply conservative limits on crediting where traceability beyond the first buyer cannot be established.
3.8 Start date and prior consideration
The project shall define a clear project start date. The project proponent shall identify the date on which the devulcanization process began operating for eligible feedstock and producing eligible reclaimed rubber output.
Where required by PCS rules, the project proponent shall demonstrate prior consideration of carbon finance through contemporaneous evidence. Absence of credible contemporaneous evidence, where required, shall render the project ineligible.
3.9 Monitoring system eligibility
Eligibility under this methodology is conditional on auditable monitoring. The project shall have a monitoring system capable of producing complete and auditable records for all parameters required to quantify emission reductions for each monitoring period.
Monitoring shall include feedstock quantity determination, rejection and contamination handling, processing throughput, product output quantities, energy consumption, any consumables that materially affect emissions, and evidence of downstream use and substitution for credited quantities.
If monitoring is not feasible at validation for the parameters required by this methodology, the project shall not be eligible for registration under this methodology.
3.10 Material change controls
The project proponent shall disclose any material change that may affect applicability, baseline, additionality, monitoring, substitution claims, or quantification. Material changes include changes in feedstock sourcing area, feedstock composition, process technology, process energy intensity, product specifications, eligible application list, substitution ratios, buyer structure, or traceability controls.
Where a material change occurs, the project proponent shall follow PCS procedures for post-registration changes and shall obtain approval where required prior to claiming credits for the affected period.
3.11 Specific exclusion triggers
A project shall be deemed not eligible under this methodology where any of the following apply. Feedstock traceability is not auditable. Baseline end-of-life tire management cannot be credibly established. Substitution cannot be evidenced or functional equivalence cannot be demonstrated conservatively. Diversion from existing recycling pathways is material and not addressed. Double counting risk exists due to overlapping claims and cannot be managed. Monitoring cannot produce auditable input-output and energy datasets.
3.12 Eligibility evidence requirements
Eligibility shall be supported by documentary evidence sufficient for validation and verification. Evidence shall be traceable, dated where relevant, and auditable.
Table 3-1. Minimum eligibility evidence (non-exhaustive)
Project description and process
Process narrative, equipment list, process flow diagram, capacity, operating conditions
Permits and compliance
Waste handling permits, environmental approvals, safety documentation
Feedstock sourcing and traceability
Supplier agreements, collection logs, weighbridge tickets, transport records, inbound inspection records
Baseline waste pathway
Market/sector evidence, waste management data, regional pathway justification, allocation across pathways where applicable
Product specification
Output specs, quality control tests, batch records
Substitution and functional equivalence
Technical justification, formulation limits, conservative substitution ratios and basis
Downstream use evidence
Sales invoices, contracts, delivery notes, buyer declarations where applicable
Non-overlap / double counting
Contracts and declarations on attribute ownership and claims, non-overlap statements
Monitoring feasibility
Meter register, calibration plan/records, monitoring procedures, QA/QC procedures
Material change control
Change control procedure and records
Chapter 4 - Project Boundary
4.1 Boundary principle
The project boundary shall include all emission sources and material flows necessary to quantify, in a complete and conservative manner, the net emission reductions attributable to devulcanization of eligible end-of-life tires and the downstream substitution of baseline materials. The boundary shall be defined such that baseline and project scenarios are comparable and exclusions do not result in over-crediting.
The boundary for this methodology is a substitution system. It includes the project processing system that converts end-of-life tires into reclaimed rubber output and the baseline material production displaced by that output, together with the baseline end-of-life tire management pathway avoided by diverting tires to the project.
4.2 Boundary components
The project boundary shall include the following components where material and measurable.
The boundary shall include inbound receipt of eligible end-of-life tires and on-site processing steps necessary to produce reclaimed rubber, including pre-processing steps that are integral to devulcanization such as shredding, grinding, separation, devulcanization reactions or thermal treatment, and finishing steps required to meet the output specification.
The boundary shall include project energy consumption for processing, including electricity and fuels consumed on-site for devulcanization and associated equipment.
The boundary shall include consumables and process inputs where they are material to project emissions and can be monitored, including chemicals or additives used in chemical devulcanization processes.
The boundary shall include transport emissions only where required by PCS or where transport is material, attributable, and measurable and where inclusion is necessary to prevent over-crediting. If transport is included, it shall be limited to transport legs that are attributable to the project and that differ materially from the baseline scenario.
The boundary shall include baseline end-of-life management of the tires that would have occurred in the absence of the project. Baseline pathways may include landfilling, stockpiling, open dumping, incineration, co-processing, or other regional practices, subject to credibility and conservative treatment rules in Chapter 5.
The boundary shall include baseline production of the displaced material, defined as the production of the baseline rubber input that is substituted by the project reclaimed rubber output.
4.3 Greenhouse gases included
Emissions shall be quantified as CO₂e. Project emissions shall include CO₂, CH₄, and N₂O where relevant to fuel combustion for project energy use and where emission factors include those gases.
Where baseline waste pathways involve CH₄ emissions, such as landfilling of tires under conditions that generate methane from associated organic fractions or co-disposal interactions, inclusion shall follow the baseline pathway rules in Chapter 5 and shall be conservative and evidence-based.
Where baseline pathways involve combustion, baseline emissions shall include relevant combustion GHGs.
This methodology does not quantify removals. No removals shall be claimed under PCS-TR-011.
4.4 Mass balance and traceability boundary rules
The project shall implement a mass balance that reconciles inbound tire feedstock, rejected materials, processing losses, and output product quantities. The boundary shall be defined such that all eligible credited output can be traced back to eligible feedstock inputs through auditable batch records and inventory accounting.
Where the facility processes both eligible and non-eligible feedstock, the project shall implement segregation or auditable allocation methods that prevent claiming substitution benefits for non-eligible feedstock. Where allocation is applied, it shall be conservative and shall not increase credited output.
4.5 Multi-output treatment
Where the project produces multiple output streams, only the reclaimed rubber output used for eligible substitution applications may be credited under this methodology. Outputs used for energy recovery, low-grade applications without substitution evidence, or disposed residues are excluded from substitution crediting.
Where by-products are sold and could plausibly substitute other baseline materials, such substitution shall not be credited under this methodology unless explicitly included through PCS-approved provisions and robust evidence, because multi-claiming risks are high.
4.6 Boundary exclusions
Upstream lifecycle emissions from manufacturing and construction of the devulcanization plant are excluded. Emissions from unrelated facility activities that are not causally linked to processing eligible tires and producing eligible reclaimed rubber are excluded.
The boundary shall not exclude any element where exclusion would result in over-crediting through unaccounted processing energy, unaccounted rejected feedstock, unaccounted non-eligible feedstock, or unaccounted diversion from existing recycling pathways.
4.7 Boundary table
Table 4-1. Boundary sources and inclusion status (tire devulcanization)
Baseline end-of-life tire management emissions
Yes
No
Avoided baseline pathway is a component of baseline scenario.
Baseline production of displaced rubber input
Yes
No
Represents avoided material production due to substitution.
Project processing energy emissions
No
Yes
Represents emissions from devulcanization processing.
Project process consumables
Conditional
Conditional
Included where material and measurable.
Project transport attributable to activity
Conditional
Conditional
Included only where required or material and measurable.
Non-eligible feedstock processing
No
No
Excluded from crediting; must be segregated/allocated conservatively.
Outputs used for energy recovery
No
No
Not eligible for substitution crediting under this methodology.
4.8 Documentation requirements
The project proponent shall provide boundary documentation sufficient for validation and verification. Documentation shall include a boundary narrative, process flow diagram, description of metering and monitoring points, mass balance approach, feedstock eligibility and segregation/allocation procedures, product output definitions and eligible applications, and justification for inclusion or exclusion of transport and consumables.
Failure to demonstrate an unambiguous and conservative boundary definition and auditable mass balance and traceability shall render the project ineligible for issuance for the affected periods.
Chapter 5 - Baseline Scenario and Baseline Emissions
5.1 Baseline principle
The baseline scenario shall represent the GHG emissions that would occur in the absence of the project activity for the same eligible tire feedstock and for the materials that are substituted by the project reclaimed rubber output. The baseline shall be defined in a transparent, conservative, and verifiable manner and shall not be selected or structured to inflate emission reductions.
Baseline emissions under this methodology comprise two elements. The first element is emissions associated with baseline end-of-life management of the tires that are collected and processed by the project. The second element is emissions associated with baseline production of the material(s) that are substituted by the eligible reclaimed rubber output.
The project shall not credit reductions where either baseline element cannot be credibly established or where substitution cannot be evidenced.
5.2 Identification of the baseline end-of-life tire management scenario
The project shall identify the baseline end-of-life management pathway(s) that would have occurred for the eligible tires in the absence of the project. Baseline pathways may include landfill disposal, controlled incineration without energy recovery, controlled incineration with energy recovery, use as tire-derived fuel, pyrolysis, crumbing or other recycling pathways, export, or other regionally relevant pathways.
The baseline pathway selection shall be evidence-based and representative of the sourcing geography and market conditions. The project shall justify the baseline pathway share where multiple pathways exist and shall apply conservative assumptions where uncertainty exists.
The baseline shall not be defined as an extreme or atypical disposal pathway unless it is demonstrably representative. Where baseline pathways vary across the sourcing area, the project shall disaggregate pathways or apply conservative allocation that does not overstate baseline emissions.
Where non-compliant or illegal practices exist, the project shall not assume such practices as baseline without credible evidence of prevalence and continuity. If such practices are asserted as baseline, the project shall apply conservative treatment consistent with PCS requirements and shall demonstrate that the baseline is not inflated by unverified assumptions.
5.3 Baseline production of substituted material scenario
The project shall identify the baseline material(s) that are substituted by the eligible reclaimed rubber output. The baseline substituted material is normally virgin rubber or other rubber input that would have been used in the absence of the project reclaimed rubber, for the same downstream application.
The project shall define the functional unit for substitution claims and demonstrate that the project output used in an eligible application displaces baseline material on that functional unit basis. Where the project output is blended or used at limited inclusion rates, the project shall apply conservative substitution ratios reflecting the actual displacement of baseline material.
The project shall not assume that use of reclaimed rubber automatically displaces virgin rubber unless displacement is credible for the defined application and supported by evidence.
5.4 Baseline quantities for the monitoring period
Baseline quantities for monitoring period shall be linked to monitored project activity.
The baseline end-of-life management quantity shall be the quantity of eligible tires processed by the project in period , adjusted for any ineligible feedstock, contaminants, or quantities that are rejected and not devulcanized.
The baseline substituted material quantity shall be the quantity of eligible reclaimed rubber output that is sold or transferred and evidenced as used in eligible substitution applications in period , multiplied by the conservative substitution ratio applicable to the use case.
Where output is produced but not sold or not evidenced as used in eligible substitution applications, the associated baseline substituted material quantity shall be treated as zero for crediting.
5.5 Baseline emissions calculation structure
Baseline emissions for monitoring period shall be calculated as the sum of baseline emissions from tire end-of-life management and baseline emissions from production of substituted materials, consistent with the boundary definition in Chapter 4.
Table 5-1. Baseline emissions accounting structure
Baseline end-of-life management emissions
Baseline substituted material production emissions
Total baseline emissions
5.6 Baseline end-of-life management emissions
Baseline end-of-life management emissions shall be calculated using the baseline pathway shares and the applicable emission factors for those pathways, applied to the eligible tire quantity attributable to each pathway.
Table 5-2. Baseline end-of-life emissions equation
Baseline end-of-life emissions

Where:
is the quantity of eligible tires attributed to baseline pathway
in monitoring period
(tonnes or other defined unit).
is the emission factor for baseline pathway
(tCO₂e/tonne), selected from credible sources and applied conservatively.
Where the baseline pathway includes landfill disposal and PCS requires inclusion of methane from disposal, the project shall apply a PCS-approved approach or conservative factors consistent with PCS guidance for waste disposal emissions.
5.7 Baseline substituted material production emissions
Baseline substituted material production emissions shall be calculated by applying an emission factor for the baseline substituted material to the quantity of baseline material displaced by the eligible reclaimed rubber output, adjusted by the conservative substitution ratio.
Table 5-3. Baseline material production emissions equation
Baseline substituted material production emissions
![]()
Where:
is the quantity of eligible reclaimed rubber output evidenced as used in eligible application
during monitoring period
(tonnes).
is the conservative substitution ratio for application
, representing the amount of baseline material displaced per unit of project output used.
is the emission factor for production of the baseline substituted material for application
(tCO₂e/tonne), selected from credible sources and applied consistently.
Where application-specific baseline materials differ, the project shall disaggregate by application and shall not apply a single high emission factor across applications unless doing so is conservative relative to actual displacement.
5.8 Baseline validity, updating, and material changes
Baseline assumptions shall remain valid only where they continue to represent baseline tire end-of-life management and baseline substituted material production for the sourcing context and downstream applications.
Where market conditions, regulations, recycling obligations, or waste pathway availability materially change baseline end-of-life management, the project shall update baseline pathway shares and emission factors in accordance with PCS requirements and in a manner that avoids over-crediting.
Where downstream application mix or substitution ratios change materially, the project shall update substitution ratios and baseline material factors as required and shall apply conservative treatment.
5.9 Documentation requirements
The project proponent shall document baseline scenario identification for end-of-life pathways and substituted materials, baseline pathway share evidence, baseline emission factor sources, substitution basis and functional unit definition, conservative substitution ratios and supporting evidence, downstream use evidence linking output to eligible applications, and calculation files sufficient for independent replication.
Chapter 6 - Additionality
6.1 Requirement
The project activity shall be additional. The project proponent shall demonstrate that, in the absence of carbon credit revenues, the devulcanization activity would not have occurred as implemented, would not have occurred at the same scale and timing, or would not have delivered the same verified substitution outcomes.
Additionality shall be assessed at validation. Where PCS requires reassessment at renewal or where material changes occur that affect the additionality basis, additionality shall be reassessed in accordance with PCS procedures.
6.2 Regulatory surplus and mandate test
The project shall not be eligible where devulcanization of the relevant waste stream is legally mandated for the project proponent or is required by an enforceable permit condition, binding extended producer responsibility obligation, or other enforceable obligation that results in equivalent devulcanization or equivalent material recycling outcomes absent the project.
Where recycling targets, landfill bans, or EPR schemes exist but do not mandate devulcanization specifically, the project proponent shall demonstrate that credited outcomes exceed compliance and are not simply the result of regulatory obligations. The project proponent shall disclose all relevant regulatory requirements and demonstrate that credited benefits are not double counted against compliance instruments or reported targets in a way that conflicts with PCS requirements.
6.3 Investment analysis or barrier analysis
The project proponent shall demonstrate additionality using either an investment analysis or a barrier analysis, supported by auditable evidence reflecting information available at the time of the decision to implement the project.
6.3.1 Investment analysis
Where investment analysis is applied, the project proponent shall demonstrate that the devulcanization project is not financially attractive without carbon revenues or that carbon revenues are decisive to meeting an investment threshold required by decision-makers.
The analysis shall include capex and opex for devulcanization equipment, pre-processing, utilities, maintenance, labour, waste handling, quality control, compliance costs, and any necessary infrastructure. The analysis shall include all material revenues including sales of reclaimed rubber output, by-product revenues, tipping fees or gate fees, grants, subsidies, and tax incentives, and shall include avoided disposal costs where relevant.
The project shall not omit material benefits that would materially affect the conclusion. Sensitivity analysis shall be conducted for material parameters such as reclaimed rubber sales price, feedstock gate fee, energy prices, plant utilisation, and yield.
6.3.2 Barrier analysis
Where barrier analysis is applied, the project proponent shall demonstrate at least one credible barrier that would prevent implementation of devulcanization at the stated scale and timing in the absence of carbon revenues, and that the project overcomes the barrier.
Barrier claims may include limited access to finance, technology performance risk, product quality acceptance barriers, market uptake barriers for reclaimed rubber, supply chain and sourcing constraints for eligible tires, permitting and compliance complexity, or contractual barriers. Barrier claims shall be facility-specific, evidenced, and causally linked to the implementation decision. Generic claims that recycling is difficult or that the market is uncertain without evidence shall not be accepted.
6.4 Common practice assessment
The project proponent shall assess whether devulcanization and the credited substitution pathway are common practice in the applicable context, considering geography, market structure, regulatory environment, and supply chain availability.
If devulcanization at similar scale and product quality is already widely implemented without carbon finance and the activity is financially attractive or effectively mandated through market structure, the project shall not be eligible unless the project proponent demonstrates material differences that affect likelihood of implementation and are not driven by legal requirements.
6.5 Double counting and overlapping claims as an additionality risk
Additionality is not satisfied if the project is effectively monetising benefits that are already claimed or required under another mechanism. The project shall disclose any recycled content claims, producer responsibility reporting, or corporate environmental claims associated with the reclaimed rubber output.
Where downstream buyers claim recycled content or emissions benefits and those claims overlap with the project’s substitution crediting, the project shall demonstrate that claims are managed in a manner consistent with PCS requirements. Where overlap cannot be managed, conservative treatment shall be applied, including exclusion of affected output quantities from crediting.
6.6 Timing integrity and prior consideration
Where required by PCS rules, the project proponent shall demonstrate prior consideration of carbon finance through contemporaneous evidence. Absence of credible contemporaneous evidence, where required, shall render the project ineligible.
Where the devulcanization facility began operation for eligible feedstock prior to entering PCS, the project proponent shall demonstrate eligibility under PCS rules applicable to start date and prior consideration and shall not claim reductions for periods that do not meet PCS timing requirements.
6.7 Additionality failure conditions
A project shall be deemed not additional where devulcanization is legally mandated, where the investment analysis demonstrates financial attractiveness without carbon revenues and the project cannot show carbon revenue is decisive, where tipping fees and sales revenues already make the project business-as-usual, where claimed barriers are not supported by facility-specific evidence, where the activity is common practice without credible differentiation, or where timing and prior consideration requirements are not met.
6.8 Documentation requirements
The project proponent shall provide documentation sufficient for validation. Documentation shall include the regulatory analysis, the selected additionality demonstration method and supporting evidence, common practice evidence and analysis, disclosure of grants, subsidies, tipping fees, and other support mechanisms, and any prior consideration evidence required by PCS rules. Documentation shall be traceable, dated where relevant, and auditable.
Chapter 7 - Project Emissions and/or Removals
7.1 Principle
Project emissions shall include all GHG emissions within the project boundary that are attributable to the project scenario and that are relevant to the quantification of net emission reductions under this methodology.
For tire devulcanization projects, project emissions primarily arise from electricity consumption and on-site fuel combustion associated with pre-processing, devulcanization, separation, drying, and auxiliary systems. Where process consumables or wastes materially contribute to emissions and are quantifiable, they shall be included in accordance with PCS requirements and the conservative principles of this methodology.
This methodology does not quantify removals. No removals shall be claimed under PCS-TR-011.
7.2 Project activity data boundary for emission accounting
Project emissions shall be quantified for the facility processes that are required to produce eligible reclaimed rubber output from eligible end-of-life tire feedstock.
Where the facility processes multiple feedstocks or produces multiple product streams, project emissions shall be allocated conservatively to the eligible output quantities credited under this methodology. Allocation shall be based on auditable physical relationships such as mass throughput, energy metering by line, or other conservative allocation keys that can be verified.
Where conservative allocation cannot be demonstrated, the project shall not credit output quantities for which associated emissions cannot be attributed conservatively.
7.3 Electricity consumption emissions
Electricity consumption attributable to the devulcanization project processes shall be monitored and quantified for each monitoring period . Electricity emissions shall be calculated using the applicable electricity emission factor for the relevant electricity system and period.
Where electricity is consumed across more than one electricity system, the project shall disaggregate electricity consumption and apply the applicable emission factor(s), or apply a conservative approach that does not overstate reductions.
7.4 On-site fuel combustion emissions
Where fuels are combusted on-site to provide process heat, steam, drying, or equipment operation, such combustion emissions shall be included as project emissions using applicable fuel emission factors, including non-CO₂ components where required.
Fuel quantities shall be monitored using meters, purchase and stock reconciliation, or other auditable methods. Where multiple fuels are used, emissions shall be calculated separately for each fuel.
7.5 Process consumables and chemicals
Where the devulcanization process uses consumables or chemicals that materially affect project emissions and where PCS requires their inclusion, the project shall quantify such emissions using monitored consumption and applicable emission factors.
Where such emissions are excluded, the project proponent shall demonstrate that exclusion is conservative and that the consumables are not material to the net emission reduction estimate. Exclusion shall not be used to avoid accounting for material emissions sources.
7.6 Rejects, residues, and waste handling
The project shall monitor quantities of rejects, residues, and waste outputs generated by the process, including contaminants, fibre, steel, fines, and other separated fractions.
Where rejects are disposed to landfill, incinerated, or otherwise treated, the project shall track the pathway and assess whether associated emissions must be included as project emissions or leakage under PCS requirements. Where exclusion of such emissions could result in over-crediting, conservative inclusion or conservative deductions shall be applied.
Where separated steel is recovered and sold, the project shall not claim additional substitution benefits for steel recycling under this methodology unless explicitly allowed by PCS and supported by auditable displacement evidence. In the absence of such allowance, steel recovery shall be treated as neutral for crediting purposes, while associated handling energy is included in project emissions where within the boundary.
7.7 Project emissions calculation
Project emissions for monitoring period shall be calculated as the sum of electricity emissions, on-site fuel combustion emissions, and any included consumables or waste treatment emissions attributable to credited output quantities.
Table 7-1. Project emissions accounting structure
Electricity emissions
Fuel combustion emissions
Consumables emissions (if applicable)
Waste handling emissions (if applicable)
Total project emissions
![]()
Electricity emissions shall be calculated as:
Where is monitored electricity consumption attributable to credited outputs (MWh) and
is the applicable electricity emission factor (tCO₂e/MWh).
Fuel combustion emissions shall be calculated as:
Where is project fuel consumption of fuel
and
is the applicable emission factor (tCO₂e/unit).
Where consumables or waste pathway emissions are included, they shall be calculated using monitored quantities and applicable emission factors and shall be allocated conservatively to credited output.
7.8 Excluded project emissions
Upstream lifecycle emissions from manufacturing and construction of plant equipment and infrastructure are excluded.
Transport emissions are excluded unless PCS requires inclusion or the project demonstrates that transport is material and directly attributable within an auditable scope.
Downstream manufacturing emissions from use of reclaimed rubber in products are excluded, except that baseline material production emissions are accounted for in baseline substitution claims under Chapter 5.
7.9 Documentation requirements
The project proponent shall document the determination of project electricity and fuel consumption, meter configuration and calibration, allocation approach where required, consumables use where applicable, rejects and residue quantities and pathways, electricity and fuel emission factor selection, and calculation procedures. Documentation shall include source records such as meter datasets, invoices, stock reconciliation, laboratory records where applicable, waste transfer notes, and calculation files sufficient for independent replication.
Chapter 8 - Leakage
8.1 Principle
Leakage is an increase in GHG emissions that occurs outside the project boundary and is attributable to the implementation of the project activity. Leakage shall be assessed and included in the net emission reduction calculation where it is measurable, attributable, and material.
For tire devulcanization projects, leakage risk is primarily associated with diversion of tires from other recycling pathways, displacement of existing reclaimed rubber markets rather than virgin rubber, shifting of baseline end-of-life management pathways due to project sourcing, and emissions associated with downstream handling that are outside the project boundary but attributable and material under PCS requirements.
8.2 Leakage assessment requirement
The project proponent shall assess leakage based on feedstock sourcing, regional waste management pathways, market structure for reclaimed rubber, and buyer behaviour. Leakage assessment is mandatory.
Where leakage sources are plausible and material, leakage shall be quantified conservatively and deducted from emission reductions. Where leakage cannot be quantified credibly and the risk is material, the project shall apply conservative deductions up to and including exclusion of affected output quantities from issuance for the monitoring period.
8.3 Diversion leakage from existing recycling pathways
Leakage may occur where the project sources end-of-life tires that would otherwise have been materially recycled through an existing pathway that already provides comparable material substitution benefits.
Where such diversion is plausible, the project shall assess the baseline recycling market and demonstrate that credited tire quantities represent net diversion from the baseline end-of-life pathway(s) rather than displacement of an existing recycling activity.
Where diversion cannot be excluded, the project shall quantify diversion leakage conservatively by deducting the baseline benefits that would have occurred through the displaced recycling pathway, or by excluding affected quantities from crediting where conservative quantification is not feasible.
The project shall not claim full baseline end-of-life diversion benefits for tire quantities that would have been recycled anyway in the absence of the project.
8.4 Market leakage and substitution integrity
Leakage may occur where the project reclaimed rubber output displaces other reclaimed material rather than virgin rubber, resulting in limited or no net avoided baseline material production emissions.
The project shall address market leakage by restricting crediting to applications and buyer arrangements where displacement of baseline materials is credible and evidenced. Where evidence indicates that reclaimed rubber is primarily displacing other reclaimed rubber, conservative substitution ratios shall be applied or affected quantities shall be excluded from substitution crediting.
Where the project cannot demonstrate that the credited output results in displacement of baseline material on a conservative basis, the associated substitution component of baseline emissions shall be reduced accordingly.
8.5 Cross-border and geographic shifting effects
Where tire sourcing or product sales involve cross-border movements that materially affect baseline pathways or substitution claims, the project shall assess whether baseline assumptions remain valid and whether leakage occurs through shifting of waste management outcomes to other jurisdictions.
Where geographic shifting is plausible and material, the project shall apply conservative treatment, including disaggregated baseline pathway shares, conservative emission factors, or exclusions where credibility cannot be established.
8.6 Treatment of rejects and residues outside the boundary
Where rejects and residues are transported and treated outside the project boundary and such treatment is attributable to the project and material, the project shall assess whether associated emissions constitute leakage.
Where the project sends rejects to landfill, incineration, or other pathways and such flows are material relative to credited quantities, the project shall quantify associated emissions as project emissions or leakage, as appropriate under PCS requirements. Where quantification is not feasible, conservative deductions shall be applied.
8.7 Leakage quantification
Where quantified, leakage emissions for monitoring period shall be calculated and deducted from emission reductions.
Table 8-1. Leakage accounting structure
Diversion from existing recycling
Market displacement leakage
where quantified, or treated through reduced substitution ratio
Reject/residue treatment outside boundary
where applicable
Total leakage
![]()
Diversion leakage may be treated through exclusion of diverted quantities or through a conservative deduction equal to the baseline benefits that would have occurred through the displaced pathway.
Market leakage may be treated through conservative substitution ratios or deductions where quantified.
8.8 Documentation requirements
The project proponent shall document leakage assessment, inclusion or exclusion rationale, diversion risk assessment and evidence, buyer and application evidence supporting substitution integrity, any conservative substitution ratio adjustments used to manage market leakage, reject and residue tracking and pathway evidence, and any leakage calculations performed. Evidence shall be sufficient to allow validation and verification of leakage conclusions.
Chapter 9 - Net GHG Impact and Crediting
9.1 Principle
Emission reductions credited under this methodology shall be calculated for each monitoring period as the net difference between baseline emissions and the sum of project emissions and leakage emissions. Crediting shall be based on monitored and verifiable data. No crediting shall be issued for reductions that are not supported by auditable records.
Crediting under this methodology is driven by two controls. Eligible feedstock quantities shall be traceable and attributable to baseline end-of-life management pathways, and eligible reclaimed rubber output quantities shall be evidenced as used in eligible substitution applications with conservative substitution ratios. If either control is weak, conservative deductions shall apply up to and including exclusion of affected quantities.
9.2 Net emission reductions
Net emission reductions for monitoring period shall be calculated as follows.
Table 9-1. Net emission reduction equation
Net emission reductions
Where:
is emission reductions in monitoring period
(tCO₂e).
is baseline emissions in monitoring period
(tCO₂e), determined in Chapter 5 as
.
is project emissions in monitoring period
(tCO₂e), determined in Chapter 7 and attributed conservatively to credited output quantities.
is leakage emissions in monitoring period
(tCO₂e), determined in Chapter 8, including diversion and residue leakage where applicable.
Emission reductions shall not be claimed for periods in which . Where
is negative, it shall be reported and shall not be carried forward to offset positive emission reductions in other monitoring periods.
9.3 Creditable quantities and issuance conditions
Crediting shall apply only to eligible reclaimed rubber output quantities that meet all of the following conditions for the monitoring period. The output quantity is produced from eligible and traceable end-of-life tire feedstock. The output quantity meets defined product specifications and quality controls relevant to eligible substitution applications. The output quantity is sold or transferred and evidenced as used in eligible substitution applications during the monitoring period or within the evidence rules defined by PCS. The substitution ratio applied is conservative and supported by evidence for the relevant application. Double counting and overlapping claims are addressed in accordance with PCS requirements.
Output quantities that are stockpiled, discarded, used for energy recovery, or cannot be linked to eligible substitution use shall be assigned zero substitution credit.
Where the facility processes mixed feedstock and cannot demonstrate conservative allocation of emissions and outputs to eligible feedstock and eligible output streams, credited quantities shall be reduced conservatively or deemed ineligible for issuance.
Issuance shall occur only after successful verification and PCS review in accordance with PCS procedures.
9.4 Treatment of multiple baseline pathways and application mixes
Where baseline end-of-life pathways vary across the sourcing area, the project shall apply baseline pathway shares conservatively and disaggregate where required to avoid over-crediting. Where pathway shares cannot be evidenced for portions of the feedstock, conservative pathway allocation shall be applied.
Where the reclaimed rubber output is used across multiple downstream applications with different substitution ratios or baseline material emission factors, the project shall disaggregate by application. The project shall not apply a single high emission factor or a one-to-one substitution ratio across all applications unless doing so is conservative relative to verified use.
9.5 Treatment of rejects, yields, and mass balance integrity
Crediting shall not be based on inbound tire quantities alone. Crediting shall reflect the eligible reclaimed rubber output quantities evidenced as used in substitution applications and the baseline end-of-life pathway emissions attributable to the tires processed.
The project shall maintain a mass balance for inbound tires, reclaimed rubber output, steel fraction, fibre fraction, fines, moisture loss, rejects, and other outputs. Where yields are inconsistent with process capability or where mass balance closure is weak, conservative deductions shall be applied to credited quantities and emission reductions.
9.6 Rounding and units
Mass quantities shall be expressed in tonnes. Energy quantities shall be expressed in kWh or MWh. Emissions and emission reductions shall be expressed in tCO₂e.
Rounding shall be applied conservatively. Where rounding is required, values shall be rounded down to the nearest whole unit at the stage of credit issuance. Intermediate calculations shall retain sufficient decimal precision to avoid systematic inflation of results.
9.7 Crediting period and renewal
The crediting period length, renewal rules, and any limits on total crediting duration shall be applied in accordance with PCS requirements. The project proponent shall apply baseline update and additionality reassessment requirements applicable at renewal, including changes in waste management policies, EPR obligations, and market conditions that affect baseline pathways and substitution integrity.
9.8 Documentation requirements
For each monitoring period, the project proponent shall provide a complete calculation record that includes eligible feedstock quantities and baseline pathway allocation, eligible reclaimed rubber output quantities by application with substitution ratios and use evidence, project electricity and fuel consumption attributed to credited outputs, any consumables and residue flows included, leakage assessment and deductions, and the full calculation of net emission reductions. Records shall be sufficient to support validation and verification.
Chapter 10 - Monitoring Requirements
10.1 Objective
The objective of monitoring under this methodology is to produce complete, accurate, and auditable data sufficient to quantify baseline emissions, project emissions, leakage where applicable, and net emission reductions for each monitoring period. Monitoring shall enable independent verification of feedstock eligibility and traceability, processing throughput and yields, eligible output quantities, downstream use in eligible substitution applications, energy consumption and other material emissions drivers, rejects and residue handling, and any conservative allocations applied.
Monitoring shall be implemented as a system. The system shall include traceability procedures, measurement and metering arrangements, data collection and storage procedures, QA/QC controls, mass balance reconciliation, change control, and record retention practices.
10.2 Monitoring period
The project proponent shall define monitoring periods in accordance with PCS requirements. For each monitoring period, the project shall compile monitored data and supporting evidence that cover the full period without gaps. Where data gaps occur, the project proponent shall apply conservative treatment as set out in this chapter.
10.3 Parameters to be monitored
The project proponent shall monitor the parameters in Table 10-1, as applicable to the project configuration and credited output claims. Where a parameter is not applicable, the project proponent shall justify non-applicability and demonstrate that exclusion does not result in over-crediting.
Table 10-1. Monitoring parameters (minimum)
(Q^{IN}_{t})
Eligible inbound tire feedstock received in period (t)
tonnes
All projects
Continuous; aggregated per period
Weighbridge tickets, inbound logs
Cross-checks; segregation controls
Feedstock traceability
Source, route, legality, eligibility
N/A
All projects
Continuous
Supplier agreements, transport docs, inspections
Audit trail; non-overlap checks
Rejected/ineligible feedstock
Contaminants, non-eligible tires
tonnes
All projects
Continuous
Inbound inspection records
Conservative exclusion
(Q^{PROC}_{t})
Feedstock processed in period (t)
tonnes
All projects
Continuous
Line logs, batch records
Reconciliation to inbound
(Q^{OUT}_{t})
Reclaimed rubber output produced
tonnes
All projects
Continuous
Batch records, production logs
Mass balance checks
(Q^{CRED}_{a,t})
Eligible output dispatched and evidenced as used in application (a)
tonnes
Credited outputs
Continuous; aggregated per period
Sales invoices, delivery notes, buyer evidence
Traceability; completeness
Output quality metrics
Specs supporting eligible use
Various
All credited outputs
Per batch/lot or per QC plan
Lab tests, QC records
Method consistency; traceability
Electricity consumption (EC_{t})
Electricity used attributable to credited outputs
MWh
All projects
Continuous; aggregated
Electricity meters, utility bills
Calibration; allocation controls
Fuel consumption (FC^{PJ}_{j,t})
On-site fuels used
fuel unit
Conditional
Continuous/event-based
Meters, invoices + stock reconciliation
Calibration; reconciliation
Process consumables
Chemical/solvent/additive use
kg/tonne
Conditional
Per batch or monthly
Purchase logs, batch records
Inventory reconciliation
Rejects/residues (Q^{RES}_{t})
Fibre, steel, fines, rejects
tonnes
All projects
Continuous
Separation logs, waste manifests
Mass balance checks
Reject pathway evidence
Landfill/incineration/recycling
N/A
Conditional
Continuous
Waste transfer notes, contracts
Traceability
Baseline pathway evidence
Market/pathway share basis
N/A
Baseline establishment; updates
Periodic
Regional data, studies, records
Representativeness review
Substitution ratio evidence (SR_{a})
Application-specific displacement basis
N/A
Credited outputs
At validation; update as required
Technical documentation, buyer specs
Conservative limits
10.4 Feedstock receipt, eligibility screening, and traceability
The project shall implement controls to ensure that only eligible end-of-life tires are credited. Each inbound load shall be recorded with date, supplier/collector identity, origin area, quantity, and inspection outcome.
The project shall implement inbound inspection procedures to identify and record contamination, non-tire materials, ineligible tire types where applicable, and other ineligible components. Ineligible quantities shall be excluded from credited calculations and shall not be included in baseline end-of-life diversion accounting.
Where the project cannot demonstrate traceability to the defined sourcing area or cannot demonstrate legality and eligibility for a portion of feedstock, the portion shall be treated conservatively as ineligible unless segregation can be demonstrated.
10.5 Mass balance and throughput reconciliation
The project shall implement a mass balance system for each monitoring period to reconcile inbound eligible feedstock, processed quantities, outputs, and rejects/residues.
Mass balance shall be performed at a frequency sufficient to detect anomalies and shall be compiled for each monitoring period. Where significant unexplained losses or inconsistencies occur, conservative treatment shall be applied and affected credited quantities may be reduced or excluded.
Where the facility produces multiple output streams, the project shall maintain separate records for eligible reclaimed rubber output and non-eligible outputs and shall ensure that credits are restricted to eligible output quantities evidenced as used in eligible substitution applications.
10.6 Output product quality monitoring
Crediting depends on credible substitution. The project shall implement quality control procedures sufficient to demonstrate that reclaimed rubber output meets the specifications required for eligible downstream applications.
Quality monitoring shall include batch or lot identification and test records relevant to performance and compatibility for the intended applications. Where quality variation affects substitution ratios or eligibility of applications, the project shall apply conservative substitution ratios or exclude affected batches from crediting.
10.7 Downstream use evidence and application tracking
The project shall collect auditable evidence that eligible reclaimed rubber output is sold or transferred and used in eligible substitution applications.
Evidence shall link quantities to buyers and applications and shall include invoices, delivery notes, contracts, and, where required, buyer declarations or technical use confirmation. Where output is sold to intermediaries and the final application cannot be evidenced, the project shall apply conservative crediting limits or exclude affected quantities.
Output that is stockpiled, returned, disposed, or used for energy recovery shall not be credited.
10.8 Energy and emissions driver monitoring
Electricity consumption shall be monitored using meters or utility bills and allocated conservatively to credited output quantities where the facility also produces non-eligible outputs or processes non-eligible feedstock.
On-site fuels shall be monitored using meters or purchase and stock reconciliation. Consumption shall be attributed conservatively to credited outputs where allocation is required.
Where process consumables materially affect emissions and are included under PCS requirements, consumables shall be monitored through purchase records, inventory changes, and batch records.
10.9 Rejects and residue tracking
The project shall monitor quantities of rejects and residues and track the pathway used for treatment or disposal. Where rejects are sent off-site, the project shall retain waste transfer notes or equivalent evidence.
Where the rejects pathway materially affects net emission reductions and must be included as project emissions or leakage, the project shall monitor quantities and retain evidence sufficient for verification.
10.10 Data quality, QA/QC, and internal controls
Monitoring data shall be subject to QA/QC controls sufficient to ensure accuracy and integrity. The project shall implement documented procedures for data collection, processing, review, and change control, including an auditable trail from raw records to reported totals.
The project shall apply internal consistency checks including reconciliation of weighbridge totals to supplier invoices, reconciliation of production logs to dispatch records, reconciliation of energy use to production rates, and review of substitution application claims for completeness and plausibility.
10.11 Data gaps and conservative treatment
Where monitored data are missing, corrupted, or otherwise unavailable, the project proponent shall apply a conservative approach to gap-filling that does not increase credited reductions.
Where feedstock traceability is incomplete, affected quantities shall be treated as ineligible unless segregation can be demonstrated. Where downstream use evidence is incomplete, affected output quantities shall not be credited. Where energy use data are missing, conservative estimates shall not reduce project emissions assigned to credited outputs. Where mass balance reconciliation fails materially, credited quantities shall be reduced or excluded.
Where credible conservative quantification cannot be demonstrated for the affected period, the project shall apply conservative deductions up to and including zero issuance for the affected period.
All data gaps and treatments shall be documented with the period affected and the impact on results.
10.12 Record retention and accessibility
The project proponent shall retain monitoring records and supporting evidence for a period consistent with PCS requirements and sufficient to allow validation and verification across the crediting period and subsequent audits.
Records shall be stored to prevent loss and unauthorised modification and shall be made available to the VVB and PCS upon request.
10.13 Monitoring report content
For each monitoring period, the project proponent shall prepare a monitoring report that includes the monitoring period definition and operational summary, inbound feedstock quantities and traceability summary, rejection handling, production throughput and yields, mass balance reconciliation results, eligible output quantities dispatched and evidenced as used in eligible applications, output quality evidence summary, energy consumption and allocation to credited outputs, fuel and consumable use where applicable, rejects and residues quantities and pathways, leakage assessment and any conservative adjustments to substitution ratios, data QA/QC and data gaps, and the full calculation of net emission reductions.
Chapter 11 - Uncertainty and Conservativeness
11.1 Principle
Uncertainty shall be managed to protect environmental integrity. Where uncertainty affects the quantification of emission reductions, the project proponent shall apply conservative approaches that avoid over-crediting.
Uncertainty treatment shall be transparent, documented, and verifiable. Weak data shall not be compensated by favourable assumptions.
11.2 Identification of uncertainty sources
The project proponent shall identify and document the sources of uncertainty that may materially affect baseline emissions, project emissions, leakage, and net emission reductions.
For tire devulcanization projects, uncertainty commonly arises from incomplete feedstock traceability, misclassification of eligible versus ineligible tires, weighbridge and measurement errors, mass balance inconsistencies and unaccounted losses, uncertainty in baseline end-of-life pathway shares, uncertainty in end-of-life emission factors, uncertainty in substitution claims and functional equivalence, overstatement of substitution ratios, buyer-use evidence gaps, allocation uncertainty for energy and emissions where multiple output streams exist, and diversion leakage risks where tires are sourced from existing recycling pathways.
Only uncertainty sources that affect the quantified net difference between baseline and project outcomes shall be considered for conservative treatment under this methodology.
11.3 Feedstock traceability and eligibility uncertainty
Feedstock eligibility is a gating condition. Where traceability is incomplete, legality cannot be demonstrated, sourcing area cannot be confirmed, or eligibility screening is weak, the project shall apply conservative treatment by excluding affected feedstock quantities from crediting.
Where mixed loads are received and segregation cannot be demonstrated, the project shall treat the affected quantities conservatively as ineligible.
The project shall not credit quantities for which inbound documentation and inspection records do not support eligibility.
11.4 Mass balance and yield uncertainty
Mass balance is the core integrity control for material recycling projects. Where inbound quantities, processed quantities, output quantities, and rejects/residues cannot be reconciled within reasonable tolerances supported by metering accuracy and process understanding, the project shall apply conservative treatment.
Conservative treatment may include reducing credited output quantities to the minimum supported by reconciled records, excluding affected batches, or excluding the monitoring period where reconciliation failure is material and cannot be corrected.
Unexplained losses shall not be treated as beneficial or ignored. Where losses occur, the project shall assess whether associated emissions or pathway shifts occur and apply conservative deductions where required.
11.5 Substitution and functional equivalence uncertainty
Substitution claims shall be conservative. Where functional equivalence is partial, variable, or not supported by technical evidence, the project shall apply conservative substitution ratios that do not overstate displacement.
Where the downstream application has formulation limits or variable inclusion rates, the project shall use substitution ratios that reflect actual displaced baseline material for the monitoring period. Where evidence is weak, the substitution ratio shall be reduced conservatively or the affected output quantities shall be excluded from substitution crediting.
The project shall not apply a one-to-one substitution assumption unless it is supported by evidence and remains conservative.
11.6 Buyer-use evidence uncertainty
Crediting is restricted to output evidenced as used in eligible substitution applications. Where sales, dispatch, or buyer-use evidence is incomplete, inconsistent, or not auditable, the project shall not credit the affected quantities.
Where the project cannot demonstrate downstream use beyond an intermediary, the project shall apply conservative limits that prevent over-crediting, including exclusion of quantities for which eligible use cannot be evidenced.
Self-declarations without supporting records shall not be treated as sufficient where they create a material risk of over-crediting.
11.7 Baseline pathway and emission factor uncertainty
Where baseline end-of-life pathway shares are uncertain, the project shall apply conservative assumptions that do not inflate baseline emissions. Where multiple plausible baseline pathways exist, the project shall either disaggregate and apply evidenced shares or apply conservative lower-emitting pathway assumptions where doing so reduces claimed reductions.
Where baseline emission factors are uncertain or vary materially, the project shall select factors conservatively and consistently and shall document applicability. The project shall not select high baseline emission factors without credible evidence.
11.8 Energy allocation and project emissions uncertainty
Where the facility has multiple output streams or processes mixed feedstock, allocation of project energy and emissions to credited outputs shall be conservative. Where allocation uncertainty exists, the project shall assign a higher share of emissions to credited outputs or exclude affected quantities where conservative allocation cannot be demonstrated.
Where energy metering is incomplete, calibration is overdue, or electricity or fuel datasets are inconsistent, conservative treatment shall not reduce project emissions assigned to credited outputs.
11.9 Leakage uncertainty and diversion risk
Where diversion from existing recycling pathways is plausible, the project shall treat uncertainty conservatively. Where diversion cannot be excluded and cannot be conservatively quantified, the project shall exclude affected quantities from crediting.
Where market displacement leakage is plausible and substitution integrity is weak, the project shall reduce substitution ratios conservatively or exclude affected quantities.
11.10 Data gaps and estimation
Data gaps increase uncertainty. Gap-filling shall not increase credited reductions.
Where credible conservative quantification cannot be demonstrated for a period, the project shall apply conservative deductions up to and including zero issuance for the affected monitoring period.
Any estimation method that materially increases emission reductions shall require explicit justification and may be rejected at verification.
11.11 Documentation requirements
The project proponent shall maintain documentation sufficient for validation and verification. Documentation shall include feedstock sourcing records, inbound inspection records, weighbridge calibration and logs, production batch records, mass balance reconciliation files, output quality test records, sales and dispatch records, buyer-use evidence, baseline pathway evidence and sources, emission factor sources, allocation procedures and datasets, rejects and residues tracking and pathway records, leakage assessment and conservative adjustments, and records of data gaps and conservative deductions applied.
Chapter 12 - Validation and Verification Guidance
12.1 Objective
This chapter defines the minimum validation and verification checks that shall be applied by the Validation and Verification Body (VVB) to determine whether the project is eligible, correctly applies this methodology, and has quantified emission reductions in a complete and conservative manner.
Where the VVB identifies non-conformities that materially affect eligibility, feedstock traceability, baseline pathway credibility, substitution integrity, allocation integrity, monitoring integrity, leakage treatment, emission factor applicability, or quantification results, the VVB shall not issue a positive opinion for registration or issuance unless the non-conformities are corrected and corrective evidence is provided.
12.2 Validation scope
At validation, the VVB shall confirm that the project meets eligibility and applicability conditions and that the project design and monitoring system can implement this methodology as written. The VVB shall assess whether the feedstock sourcing and traceability system is auditable, whether baseline end-of-life pathway assumptions are credible and representative, whether the output specification supports eligible substitution applications, whether substitution ratios are conservative, whether the monitoring system supports mass balance reconciliation and energy/emissions accounting, and whether diversion and double counting risks can be managed.
The VVB shall assess whether the project is structured to generate crediting only for eligible output quantities evidenced as used in eligible applications and whether buyer and intermediary arrangements preserve auditability.
12.3 Validation checks on eligibility and applicability
The VVB shall confirm that the project is within scope and that exclusion triggers do not apply. The VVB shall verify legal compliance and required permits for waste handling, storage, processing, and environmental operation.
The VVB shall verify the project start date and assess prior consideration requirements where applicable. The VVB shall assess the project proponent’s right to claim emission reductions and evaluate overlap risks with producer responsibility schemes, recycled content programs, and other crediting or compliance mechanisms.
The VVB shall assess whether the project feedstock is subject to legally binding recycling obligations that would result in equivalent outcomes absent the project and whether the activity remains additional.
12.4 Validation checks on boundary definition and mass balance feasibility
The VVB shall assess whether the project boundary captures all relevant process steps and monitoring points and whether the project can maintain auditable input-output accounting.
The VVB shall assess the weighbridge system, inbound inspection procedures, production batch recording, output storage and dispatch control, and rejects/residues tracking. The VVB shall confirm that the project’s mass balance approach is capable of reconciling inbound feedstock to outputs and wastes at the monitoring period level.
Where the facility produces multiple output streams or processes non-eligible feedstock, the VVB shall assess whether the project has a conservative allocation method for energy/emissions and whether allocation can be verified.
12.5 Validation checks on baseline end-of-life pathways
The VVB shall assess baseline end-of-life pathway identification and confirm that pathway shares are evidence-based and representative for the sourcing area.
The VVB shall assess whether any assumption of illegal dumping or uncontrolled burning is supported by credible evidence and whether conservative treatment is applied consistent with PCS requirements.
The VVB shall verify the emission factor sources used for baseline end-of-life pathways and confirm applicability and conservativeness.
12.6 Validation checks on substitution integrity and functional equivalence
The VVB shall assess the definition of eligible reclaimed rubber output streams, product specifications, and quality control plan. The VVB shall assess whether the proposed eligible downstream applications are credible and whether functional equivalence is demonstrated for each application.
The VVB shall assess substitution ratios and confirm that they reflect realistic displacement of baseline material given formulation limits and performance constraints. Where uncertainty exists, the VVB shall require conservative substitution ratios.
The VVB shall assess evidence requirements for downstream use and confirm that the project’s buyer and intermediary arrangements support auditability and non-overlap.
12.7 Validation checks on additionality
The VVB shall assess the additionality demonstration for completeness and credibility. The VVB shall confirm that devulcanization is not legally mandated and assess policy interactions including EPR schemes, recycling targets, and landfill restrictions.
Where investment analysis is used, the VVB shall assess whether all material revenues are included, including tipping fees, sales revenues, grants, and avoided disposal costs. Where barrier analysis is used, the VVB shall assess whether barriers are facility-specific and evidenced.
The VVB shall assess the common practice assessment and confirm that the applicable context is appropriate and that conclusions are supported by evidence.
12.8 Verification scope
At verification, the VVB shall confirm that monitoring data and calculations for each monitoring period are complete, accurate, and traceable, and that the project remains eligible under this methodology.
The VVB shall verify that feedstock sourcing area, traceability controls, process configuration, eligible output specification, buyer structure, and monitoring system have not changed in a manner that affects baseline comparability, substitution integrity, or quantification without appropriate PCS approval.
12.9 Verification checks on feedstock traceability and eligibility
The VVB shall verify inbound feedstock records, including supplier/collector records, transport documentation, weighbridge tickets, inbound inspection records, and segregation records for eligible versus ineligible feedstock.
The VVB shall confirm that credited feedstock quantities are eligible and traceable and that ineligible quantities are excluded. Where traceability is incomplete or inconsistent, the VVB shall require conservative exclusions.
12.10 Verification checks on mass balance and throughput
The VVB shall verify production records and reconcile inbound eligible feedstock quantities to processed quantities, eligible output quantities, and rejects/residues for the monitoring period.
The VVB shall assess whether any unexplained losses or inconsistencies exist and whether conservative adjustments have been applied. Where reconciliation failure is material and cannot be corrected, the VVB shall apply conservative outcomes up to and including exclusion of the affected monitoring period from issuance.
12.11 Verification checks on output quality and eligible applications
The VVB shall verify output quality records and confirm that credited output meets the specifications required for the eligible downstream applications claimed.
The VVB shall verify the eligibility of claimed applications and confirm that credited output quantities are supported by buyer evidence and technical use evidence where required. Where output quality is inconsistent with claimed applications, the VVB shall require exclusion or conservative substitution ratio reductions.
12.12 Verification checks on downstream use evidence and non-overlap
The VVB shall verify sales and dispatch records, delivery documentation, and buyer evidence linking credited quantities to eligible substitution applications.
Where intermediaries are involved, the VVB shall verify traceability controls and assess whether eligible use can be confirmed. Where eligible use cannot be evidenced, the VVB shall require exclusion of affected quantities.
The VVB shall assess double counting risk and verify any non-overlap declarations, attribute ownership clauses, and buyer claims management evidence relevant to recycled content and emissions claims.
12.13 Verification checks on project emissions and allocation
The VVB shall verify electricity and fuel consumption records and confirm that consumption is measured and allocated conservatively to credited outputs where required.
The VVB shall verify any consumables included and confirm monitored quantities and emission factor application where applicable. The VVB shall verify rejects/residues pathway evidence and confirm inclusion as project emissions or leakage where required.
Where allocation methods are used, the VVB shall verify the allocation key and confirm that allocation does not under-assign emissions to credited outputs.
12.14 Verification checks on baseline and leakage assumptions
The VVB shall verify that baseline pathway shares and emission factors remain applicable or that updates have been applied where required. The VVB shall verify substitution ratios and assess whether market conditions or buyer behaviour indicate a need for conservative adjustments.
The VVB shall verify leakage assessment, including diversion risk evaluation and any exclusions or deductions applied. Where diversion is plausible and not managed, the VVB shall require exclusion of affected quantities.
12.15 Verification checks on calculation accuracy
The VVB shall reproduce emission reduction calculations using verified inputs and shall confirm correct equations, units, aggregation, and deductions. The VVB shall confirm that emission reductions are not claimed for unsold or non-evidenced output quantities and that rounding is conservative.
The VVB shall verify that data gaps and conservative treatments are applied as required and that any estimation does not increase credited reductions.
12.16 Non-conformities and corrective actions
The VVB shall classify non-conformities based on materiality. Material non-conformities shall be corrected before a positive validation opinion or verification statement is issued.
Where corrections require changes to baseline pathway shares, feedstock eligibility datasets, substitution ratios, downstream use evidence, allocation methods, emission factors, or calculation methods, the VVB shall verify revised materials and confirm that revisions do not introduce over-crediting.
12.17 Common failure conditions under this methodology
A project shall be treated as having a material integrity failure where the VVB determines that feedstock traceability cannot be established, mass balance reconciliation fails materially, substitution cannot be evidenced, diversion risk is material and unmanaged, allocation of emissions to credited outputs is not conservative, or baseline pathway assumptions are not credible.
Where integrity cannot be established for a monitoring period, the VVB shall apply conservative outcomes up to and including zero issuance for the affected period.
12.18 Documentation requirements
The project proponent shall provide the VVB and PCS with all documents and datasets necessary to perform the checks in this chapter. Evidence shall be organised, traceable, and sufficient to support replication of results and independent assessment.
Chapter 13 - References
13.1 General requirement
The project proponent shall use credible, publicly available, and verifiable sources for all baseline pathway assumptions, emission factors for baseline end-of-life management and baseline material production, electricity and fuel emission factors, technical assumptions supporting functional equivalence and substitution ratios, and any leakage factors or deductions applied under this methodology. References shall be sufficiently specific to allow independent replication, including the title, issuing entity, version number or publication date, and the relevant sections or datasets.
Where multiple credible sources exist for a parameter, the project proponent shall justify the selection and shall apply conservative choices where uncertainty exists.
13.2 Minimum reference categories
This methodology relies on minimum reference categories where applicable. PCS documents apply, including relevant PCS standards, this methodology, any referenced PCS methodological tools, and applicable PCS templates and forms. Host country laws and regulations apply where they affect end-of-life tire collection, transport, storage, waste processing, product safety, and environmental permitting.
Authoritative sources on waste management and end-of-life tire pathways apply to establish baseline pathway shares and emission factors. Authoritative sources on electricity and fuel emission factors apply for project processing emissions. Credible sources for life-cycle or production emission factors for the substituted baseline material(s) apply for substitution accounting, with consistent functional units and conservative application. Recognised technical standards for reclaimed rubber testing and quality assurance apply where used to support eligible applications and functional equivalence.
13.3 Citation and recordkeeping requirements
All sources used shall be cited in the project documentation and retained as part of the project record. Where a dataset is updated periodically, the project proponent shall retain the specific version used for each monitoring period and demonstrate consistency with update requirements. Quality test reports, batch records, and buyer evidence supporting substitution claims shall be retained with traceability to credited quantities.
Annex A - Parameters and Default Values
A.1 General
This annex specifies the minimum parameters required to implement this methodology. Project proponents shall use measured data where required. Default values may be used only where explicitly allowed and shall be justified as applicable and conservative.
Table A-1. Parameters (minimum)
(Q^{IN}_{t})
Eligible inbound tire feedstock received in period (t)
tonnes
All projects
Weighbridge, inbound logs
Continuous; per period
No
(Q^{OUT}_{a,t})
Eligible reclaimed rubber output evidenced as used in application (a) in period (t)
tonnes
Credited outputs
Invoices, dispatch, buyer evidence
Continuous; per period
No
(SR_{a})
Conservative substitution ratio for application (a)
t displaced / t output
Credited outputs
Technical basis + buyer specs
At validation; update as required
Limited; only if PCS provides defaults
(EF^{MAT}_{a})
Emission factor for baseline substituted material for application (a)
tCO₂e/tonne
Credited outputs
Credible sources
Update as required
Limited; only if PCS-recognised defaults
(Q^{EOL}_{p,t})
Eligible tire quantity attributed to baseline pathway (p)
tonnes
All projects
Baseline pathway allocation
Per period
No
(EF^{EOL}_{p})
Emission factor for baseline pathway (p)
tCO₂e/tonne
All projects
Credible sources
Update as required
Limited; only if PCS-recognised defaults
(EC_{t})
Electricity consumption attributable to credited outputs
MWh
All projects
Meters/bills + allocation
Continuous; per period
No
(EF^{ELEC}_{t})
Electricity emission factor
tCO₂e/MWh
All projects
Official dataset(s)
Per period
Yes, where PCS recognises the source
(FC^{PJ}_{j,t})
On-site fuel use of fuel (j)
fuel unit
Conditional
Meters, invoices + reconciliation
Per period
No
(EF^{FUEL}_{j})
Fuel emission factor for fuel (j)
tCO₂e/unit
Conditional
Credible sources
Update as required
Yes, where authoritative published factors are used
(Q^{RES}_{t})
Rejects/residues and waste outputs
tonnes
All projects
Separation logs, waste manifests
Per period
No
(LE_{t})
Leakage emissions
tCO₂e
Conditional
Diversion/market/residue assessment
Per period
No
Annex B - Worked Example
B.1 Example purpose and limitations
This worked example is illustrative and demonstrates calculation logic. Project proponents shall use project-specific monitored data, conservative baseline pathway assumptions, conservative substitution ratios, applicable emission factors, and required leakage deductions.
B.2 Example scenario and inputs
Assume a project processes end-of-life tires and produces devulcanized rubber used by a manufacturer to replace virgin rubber in an eligible application. The monitoring period is one year. Baseline end-of-life management is assumed to be landfill for the relevant sourcing area for illustration only.
Table B-1. Example inputs for monitoring period
Eligible inbound tires
20,000 tonnes
Weighed and traceable
Eligible output used in application A
8,000 tonnes
Sold and evidenced as used
Substitution ratio
0.80
Conservative
Baseline material EF
2.00 tCO₂e/tonne
Example only
Baseline EOL pathway EF
0.05 tCO₂e/tonne
Example only
Electricity consumption
30,000 MWh
Monitored
Electricity EF
0.65 tCO₂e/MWh
Example only
On-site fuel emissions
0 tCO₂e
None in example
Leakage
1,000 tCO₂e
Example diversion/market deduction
B.3 Baseline end-of-life emissions
Assume 100% landfill baseline pathway for illustration.
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B.4 Baseline substituted material production emissions
Displaced baseline material quantity:
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Total baseline emissions:
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B.5 Project emissions
Electricity emissions:
Assume no on-site fuels and no included consumables for illustration.
B.6 Net emission reductions
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Under this methodology, no credits are issued for the period because the result is negative. This example illustrates why energy intensity and conservative leakage treatment matter and why projects must demonstrate net benefits with real monitored data.
B.7 Interpretation note
Where the calculation produces a negative result, the project proponent shall not adjust assumptions opportunistically to force a positive outcome. The project shall improve process efficiency, improve yield, improve energy sourcing, or revise eligible output claims to reflect verifiable net benefits.
Annex C - Monitoring Data Sheet
C.1 Monitoring log requirements
The project proponent shall maintain a monitoring log that allows independent reproduction of monitoring period totals and linkage to raw records. The monitoring log shall be maintained for each monitoring period and retained with supporting evidence.
Table C-1. Monitoring data sheet (minimum fields)
Monitoring period ID
Unique identifier
Text
Yes
Period start date/time
Start of monitoring period
YYYY-MM-DD hh:mm
Yes
Period end date/time
End of monitoring period
YYYY-MM-DD hh:mm
Yes
Sourcing area definition
Geographic boundary
Text
Yes
Supplier/collector ID
Feedstock source identifier
Text
Yes
Inbound ticket ID
Weighbridge ticket reference
Text
Yes
Inbound date
Receipt date
YYYY-MM-DD
Yes
Inbound eligible quantity
Eligible tires
tonnes
Yes
Inbound rejected quantity
Ineligible/contaminants
tonnes
Yes
Processing batch ID
Batch or run identifier
Text
Yes
Quantity processed
Feedstock processed
tonnes
Yes
Eligible output batch ID
Output batch/lot ID
Text
Yes
Eligible output produced
Output quantity
tonnes
Yes
Output QC reference
Test report refs
Text
Conditional
Dispatch invoice ID
Sales invoice reference
Text
Yes
Dispatch date
Dispatch date
YYYY-MM-DD
Yes
Buyer ID
Buyer identifier
Text
Yes
Application code
Eligible application
Text
Yes
Output used
Quantity evidenced as used
tonnes
Yes
Substitution ratio
Applied ratio
Value
Yes
Baseline material EF source/version
Text
Yes
Baseline EOL pathway share
Pathway and share
Text
Yes
Baseline EOL EF source/version
Text
Yes
Electricity consumption
MWh
MWh
Yes
Electricity EF source/version
Text
Yes
On-site fuel consumption
By fuel type
Units
Conditional
Rejects/residues
By type
tonnes
Yes
Reject pathway evidence
Waste transfer refs
Text
Conditional
Leakage assessment summary
Diversion/market/residue
Text
Conditional
Leakage emissions
tCO₂e
Conditional
Baseline emissions
tCO₂e
Yes
Project emissions
tCO₂e
Yes
Net reductions
tCO₂e
Yes
Data gaps present
Yes/No
Text
Yes
Gap treatment description
Conservative treatment
Text
Conditional
Prepared by / date
Responsible person and date
Text / YYYY-MM-DD
Yes
Internal review by / date
Reviewer and date
Text / YYYY-MM-DD
Yes
Definitions and Acronyms
D.1 Definitions
For the purposes of this methodology, the following definitions apply.
Additionality means the demonstration that the project activity results in emission reductions that would not have occurred in the absence of the project and the incentive from carbon crediting.
Baseline emissions (BE_t) means the GHG emissions that would occur in monitoring period t in the absence of the project activity, consisting of baseline end-of-life management emissions for the same tires and baseline production emissions for the material substituted by the project output.
Baseline end-of-life pathway means the waste management route that would have occurred for the end-of-life tires in the absence of the project, such as landfill, incineration, or other regionally representative pathways.
Baseline substituted material means the material input that would have been used in an eligible downstream application in the absence of the project reclaimed rubber output, typically virgin rubber or an equivalent baseline input.
Conservative substitution ratio (SR) means the ratio applied to reflect the amount of baseline substituted material displaced per unit of project reclaimed rubber output used in a defined application, reflecting functional equivalence and formulation limits and selected to avoid over-crediting.
Devulcanization means a process that breaks sulphur cross-links in vulcanized rubber to produce a reclaimed rubber material suitable for use as a material input.
Eligible application means a downstream use case for reclaimed rubber output that is approved under this methodology and for which substitution claims can be credibly evidenced.
Eligible feedstock means end-of-life tires that meet the feedstock eligibility requirements of this methodology, including traceable sourcing and non-overlap with mandated or credited recycling outcomes.
Eligible output means reclaimed rubber output that meets defined specifications and is evidenced as used in eligible applications in a manner that supports conservative substitution claims.
Feedstock traceability means the auditable chain of records linking inbound tires to defined sources, legality, quantities, processing batches, and credited outputs.
Leakage (LE_t) means an increase in GHG emissions occurring outside the project boundary that is attributable to the project activity and is measurable, attributable, and material under this methodology.
Mass balance means the reconciliation of inbound feedstock quantities to processed quantities, output quantities, and rejects/residues over a defined period to confirm the integrity of reported quantities.
Project emissions (PE_t) means GHG emissions occurring within the project boundary in monitoring period t that are attributable to the project processing activity and are allocated conservatively to credited outputs.
Rejects and residues means non-rubber fractions and waste outputs generated during processing, including fibre, steel, contaminants, and fines.
Substitution means the displacement of baseline material inputs by the project reclaimed rubber output in eligible downstream applications on a defined functional unit basis.
D.2 Acronyms
Table D-1. Acronyms
BE
Baseline Emissions
EF
Emission Factor
EOL
End-of-Life
ER
Emission Reductions
GHG
Greenhouse Gas
LE
Leakage Emissions
NCV
Net Calorific Value
PE
Project Emissions
PCS
Planetary Carbon Standard
QA/QC
Quality Assurance / Quality Control
SR
Substitution Ratio
VVB
Validation and Verification Body
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