What Is an EPD? A Verifier's Guide to Environmental Product Declarations

As someone who verifies EPDs for a living, the question I hear most often is still the most basic one: “What exactly is an EPD — is it a certificate?” The short answer: no. An EPD (Environmental Product Declaration) is an independently verified document that declares a product’s environmental impacts across its life cycle in a standardised format, in numbers. It does not say the product is “environmentally friendly”; it transparently shows how much impact the product has. The distinction may sound subtle, but it changes everything.

An analogy: an EPD is the product’s environmental “nutrition label”. The label doesn’t tell you the chocolate is healthy; it tells you what’s inside and makes comparison possible. Expressions like “EPD certificate” have settled into everyday language, but technically what you hold is a declaration — and it is only as valuable as the quality of the data behind it.

From my own practice: this is exactly the misconception I see most often in the companies that come to us. Clients assume that by obtaining an EPD they have declared their product to be “green” — they perceive it as a kind of sustainability certificate confirming how environmentally friendly the product is. An EPD gives no such endorsement; good or bad, it reports the product’s environmental impact as it is. Correcting this expectation at the very start of the process also prevents disappointment later on.

Which standards is an EPD based on?

The umbrella standard for EPDs is ISO 14025 (Type III environmental declarations). The calculations behind the declaration are based on life cycle assessment (LCA) methodology, i.e. ISO 14040 and ISO 14044. In the construction sector, two more standards come into play: EN 15804+A2 in Europe — today the common language of construction product EPDs — and ISO 21930 at the international level. Rules specific to each product group are defined in PCR (Product Category Rules) documents: which functional unit to use, which modules to declare, which data requirements apply — it is all written there.

Let me also clarify a point I frequently encounter in verification: the A2 revision of EN 15804 substantially changed the indicator set and the characterisation methods. There are still companies that benchmark against old EPDs prepared under A1 and end up disappointed; yet with different characterisation factors, different results are entirely normal — A1 and A2 results for the same product are not directly comparable.

What is inside an EPD? Modules in brief

In construction product EPDs, the life cycle is divided into modules: A1–A3 (raw material supply, transport, manufacturing — the core of most EPDs), A4–A5 (transport to the construction site and installation), B (the use stage), C (demolition, waste processing and disposal) and D (potential benefits and loads beyond the system boundary from recycling and reuse). With EN 15804+A2, declaring modules C and D became mandatory for most products — the “it ends at the factory gate” approach is now the exception, not the rule.

Each module reports a set of environmental indicators, led by global warming potential (GWP). The number buyers look at most is usually the A1–A3 GWP figure; what the verifier looks at is the data behind that number: which year the production data covers, which plants it includes, and whether the background datasets actually represent the product.

If you ask me where I see the most errors as a verifier: in the production stage, A1–A3. Incomplete data collection, consultants asking the manufacturer the wrong questions, or — where the manufacturer prepares the study in-house — the wrong data being used. A model that doesn’t start from correct data cannot be fixed later, no matter how carefully it is built. The second big topic is allocation: when energy and raw material loads shared by several products are distributed to them incorrectly, the results are directly distorted. The third is background data: the wrong technology, the wrong geography or the wrong proxies can be selected for secondary datasets. And in scenario-based modules — module C in particular — I see scenarios that are not aligned with the target market; if the product is sold to Europe, the end-of-life scenario needs to reflect the waste management reality of that market. A significant share of my verification comments concentrate on exactly these points. I covered how these errors send EPDs back from verification in Why EPDs fail long before verification.

How do you get an EPD? The realistic version of the process

The process consists of roughly five steps: (1) identifying the PCR* applicable to your product, (2) collecting production data and building the LCA model, (3) preparing the LCA report and the EPD document, (4) independent verification, (5) registration and publication through a programme operator**. Contrary to what most companies assume, the least predictable part of the timeline is not verification but data collection: if energy invoices, raw material recipes and waste records are scattered, that is where the process gets stuck.

* PCR (Product Category Rules): the document that defines the calculation methods, system boundaries, data requirements and reporting rules to be applied when preparing an EPD for a specific product group.

** Programme operator: the independent organisation that runs an EPD programme, publishes PCRs, and registers and publishes verified EPDs.

Cost is driven by the same factor. The honest answer to “how much does an EPD cost” is that it depends on the number of products, the complexity of your production sites and how ready your data is — with a solid data infrastructure the process is both fast and economical; with scattered data, everything takes longer.

On the programme operator side, from my own practice: I serve as an independent EPD verifier for The International EPD System, EPD Global, EPD Hub and the Finland-based RTS programme, and the verification process works in much the same way across all of them. The real driver of the timeline is not the operator but how cleanly the study has been prepared. For a genuinely clean study, verification can be completed in two weeks; once verification loops start multiplying — comments, revision, further comments — projects can drag on much longer. Two things make the difference: data collected correctly and systematically from the start, and the experience of the team preparing the study. The more experienced the team, the more robust the study — and the lighter the verifier’s workload.

Why an EPD is no longer just ‘nice to have’ for Turkish manufacturers

There are three concrete reasons. First, export: public tenders and large projects in the EU market increasingly ask for EPDs; in green building certification systems such as LEED and BREEAM***, products with EPDs earn points, which has made the EPD the de facto key to getting into project specifications. Second, the regulatory wave: CBAM**** demands product-level emissions data, and the Digital Product Passport will demand life cycle data — the data infrastructure you build for an EPD is the foundation for both. Third, competition: if your competitor has an EPD and you don’t, buyers now read that as a transparency gap.

*** LEED and BREEAM: international green building certification systems that assess the environmental performance of buildings.

**** CBAM (Carbon Border Adjustment Mechanism): the EU regulation under which the carbon emissions embedded in certain product groups imported into the EU must be reported and are subject to carbon pricing.

Let me also state the other side of the coin: an EPD prepared in a rush, on weak data, captures none of these opportunities. It drags through verification with extra questions, and even if published, it will not stand up to scrutiny from sophisticated buyers. An EPD is not a box-ticking exercise; it is public proof that you take your product data seriously.

Frequently asked questions

How long is an EPD valid?

In most programmes, an EPD is valid for five years from its publication date. If, within that period, changes to the product, its raw materials or its production processes significantly affect the results, the EPD must be updated earlier; when the validity period ends, it is renewed through recalculation and verification.

Is an EPD mandatory?

As of today, an EPD is a voluntary declaration in most markets — there is no general legal obligation. But the picture is changing fast: the EU’s revised Construction Products Regulation (CPR) is phasing in mandatory environmental sustainability declarations for construction products; several European countries require building-level carbon reporting, which effectively makes product data (EPDs) a necessity; and EPDs appear ever more often as a precondition in the specifications of large projects.

Do I need a separate EPD for every product?

Not necessarily. Depending on the PCR and the programme operator’s rules, products with similar raw materials and production processes can be grouped in a single EPD (a product family or average EPD). If the variation in results within the group exceeds the limits the programme allows, separate EPDs are required — the soundest approach is to make this assessment at the start of the process, based on the applicable PCR.

Who verifies an EPD?

EPDs are verified by third-party verifiers who are independent of the team that prepared the study and approved by the programme operator. The verifier reviews the LCA model, the data quality, the scenarios and the EPD document against the applicable PCR and standards. Independence is the key principle here: a verifier cannot verify a study they prepared or contributed to.

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This is exactly why, at EPDlogy, we build the process through a verifier’s eyes. We prepare LCA and EPD studies end to end with our expert team, knowing which questions will be asked in verification — that is the essence of our current strategy. Teams running their own study but stuck at some point can also consult us at any step: data collection, data selection, allocation questions or scenario design. For projects we have not prepared ourselves, we offer independent verification services. And we are ready to support product carbon footprint, CBAM and Digital Product Passport work — everything that builds on product data.