On the use of national-level LULUC data in product-level LCA: reflections on methodological alignment

We read with interest the recent publication by Lehtilä and colleagues [1], which proposes a framework for including national-level land use and land-use change (LULUC) emissions and removals in the global warming potential (GWP) of agricultural and forestry products in life cycle assessment (LCA). While the transparency and structure of the approach are appreciated, several methodological issues arise that deserve attention. • Rebuttal to Lehtilä et al.‘s framework on LULUC accounting in product-level LCA. • Framework relies on average retrospective data, limiting decision-use relevance. • Method excludes indirect land-use change and marginal dynamics. • Conceptual misalignments with GWP metric and managed-land proxy are noted. • Highlights the need for methodological coherence in LCA applications.