As long as no delegated act applies to your category, the ESPR creates no methodological requirement and there is therefore no non-compliance concerning the method itself. However, Article 9(1) requires DPP data to be "accurate, complete and up to date"; a technically indefensible method may be challenged on this basis. Once the delegated act is in force, Article 74 sets out penalties: fines and exclusion from public procurement.
Read the source article: Which method should you use to calculate a DPP (footprint, PEF, LCA)?