EPD Verification

Why the preparer and the verifier cannot be the same party

The value of an EPD comes from the fact that its numbers were checked by someone independent. Programme operators therefore require the verifier to have played no part in preparing the study — the party that gave the advice cannot verify its own work.

In practice this means the manufacturer works with two separate parties: the one that builds the LCA model and the report, and the verifier who reviews the file independently. EPDlogy can take on either role, but never both on the same project — that is what the independence rule means.

The form verification takes is always set by the rules of the relevant programme operator and the Product Category Rules (PCR) applied. For construction products, independent external verification is the standard route in practice.

What exactly is reviewed at each step

1. 11 · Scope confirmation — Which programme operator, which PCR, how many products, which modules. The verifier’s independence is confirmed at this step, and the fee and schedule are agreed.
2. 22 · Checking what was submitted — LCA report, model file or calculation sheet, primary data records, background dataset documentation and the draft declaration. An incomplete submission is the single biggest cause of delay.
3. 33 · Model and report review — System boundary, declared unit, data quality, allocation, cut-off rules, scenarios and results tables are assessed against the PCR and EN 15804+A2.
4. 44 · Verification comments — Comments arrive as one list, each stating what it is based on and what is expected — not “fix this”, but “this needs to be shown, for this reason”.
5. 55 · Revision and closing check — Responses and updated files are reviewed. Once no open items remain, the verification report and approval are issued.

A review round typically takes 1–2 weeks. The total schedule is usually 2–4 weeks, depending on how complete the file is when it first arrives.

The findings that come up most often in verification

These are the issues we meet again and again from the verifier’s seat. None of them is exotic — and almost all of them would never arise if the study were set up correctly from the start. Checking these yourself before sending a file for verification will reduce the number of rounds.

• Declared unit confused with functional unit: a declared unit is chosen, but the report never explains how it relates to the actual quantity of product in use.
• System boundary and module coverage disagree: the text says cradle-to-gate while the table reports modules C and D — or the other way round.
• Background dataset choice left unjustified: which database, which version, why that geography and that year. When these are not written down, a finding is unavoidable.
• Weak representativeness of primary data: deriving an annual average from a single month of production data cannot be defended without addressing seasonality and capacity utilisation.
• End-of-life scenarios without a basis: recovery rates are used for modules C and D, but neither their source nor their relation to market reality is shown.
• Cut-off rules applied but not reported: the PCR sets a cut-off threshold and the study applies it, but which flows were excluded is never documented.
• Allocation method not described: how the burden is distributed in multi-product plants is one of the areas verifiers question most.
• Numbers differ between the report and the declaration: the table in the LCA report and the table in the declaration do not match — usually because a last-minute model update was carried into only one of the files.

If you would like this list expanded for your own product group, get in touch.

What to look for when choosing a verifier

Choosing a verifier on price alone is a common mistake. Who the verifier is directly determines how many rounds the process takes — and therefore what it actually costs.

• Are they approved by the programme operator? The verifier has to be on the approved list of the operator you intend to publish with. This is the first and non-negotiable filter.
• Do they have experience with your PCR? Cement and timber, ceramics and insulation do not raise the same questions. A verifier with sector experience asks the right question in the first round.
• Do they meet the independence condition? Preparation and verification for the same project cannot come from the same party. This is a rule, not a preference.
• How are the comments written? Scattered comments without a stated basis cost your team weeks. A good verification comment shows what is being asked for and why.
• Do they commit to a schedule? If you have a tender or a customer deadline, the time per round should be agreed up front.

What happens after verification

Verification approval is not the end of the process but the start of publication. The approved file goes to the programme operator; once the operator completes its own registration and publication steps, the EPD is published and becomes publicly available.

An EPD is typically valid for five years. If your production process, energy source, product recipe or supplier structure changes materially within that period, the declaration may need to be updated. At the end of the period, renewal means refreshing the data and verifying it again.

Planning the renewal in time matters: a manufacturer whose EPD has expired cannot use the declaration in a tender or a green building project. Building the schedule backwards from the expiry date costs far less than a rushed renewal.