Introduction: From Decision to Declaration

You have decided that your construction product needs an Environmental Product Declaration (EPD). Perhaps a public tender requires one, or a client’s sustainability team has asked for product-level carbon data, or you want to position your product competitively in a market that increasingly rewards transparency. Whatever the motivation, the question now is practical: how do you actually get an EPD?

3–6
months from initial scoping to published EPD (typical timeline)

The process is more structured and more accessible than many manufacturers expect. It does not require in-house environmental expertise, although having a basic understanding of your production process and material inputs is essential. This article describes the six main steps of the EPD certification process, from initial scoping through to publication, and provides practical guidance on timelines, costs, and how to work effectively with the professionals involved.

Step 1: Define the Product Scope and Declared or Functional Unit

What Are You Declaring?

The first decision is what, exactly, the EPD will cover. An EPD can cover a single product, a product range, or an average across a product family. For example, a concrete manufacturer might prepare one EPD covering its entire C25/30 strength class from a specific plant, or separate EPDs for each plant. An insulation manufacturer might declare a single product type at a reference thickness or prepare a range covering multiple thicknesses and densities.

Unit Type Used For Example
Declared unit Cradle-to-gate EPDs 1 tonne of cement; 1 m³ of concrete
Functional unit Cradle-to-grave EPDs 1 m² wall insulation at 5.0 m²K/W over 50 years
Declared unit vs. functional unit

Practical Considerations

The scope directly affects the LCA workload and cost. A single-product EPD from one production facility is the simplest case. A multi-product or multi-site EPD requires aggregation rules and may need additional verification effort. Discuss scoping with your LCA practitioner and programme operator early, because changing scope mid-project adds cost and delay.

Tip: Discuss scoping with your LCA practitioner and programme operator early. Changing scope mid-project adds cost and delay.

Step 2: Identify the Applicable Product Category Rules (PCR)

What Is a PCR?

Product Category Rules are the detailed instructions that govern how an LCA is performed for a specific product group. They supplement the core rules in EN 15804+A2 with product-specific requirements: which declared unit to use, which life-cycle modules are relevant, what end-of-life scenarios to assume, which data sources are acceptable, and how to handle allocation in multi-output processes.

Every programme operator maintains a library of PCRs. EPD Polska publishes PCRs for major construction-product categories, including cement, concrete, steel, insulation, wood products, windows, and aggregates. The LCA study and the resulting EPD must comply with the specific PCR designated by the programme operator.

What If No PCR Exists for My Product?

If no existing PCR covers your product type, the programme operator can initiate a PCR development process. This involves drafting the rules, subjecting them to stakeholder review, and publishing the final PCR. The process typically adds several months to the timeline but results in a new PCR that other manufacturers in the same product category can also use.

Step 3: Commission a Life-Cycle Assessment (LCA)

Selecting an LCA Practitioner

The LCA is the technical foundation of the EPD. It must be performed by a qualified LCA practitioner with experience in the relevant product category and familiarity with EN 15804+A2, ISO 14040, and ISO 14044. Many practitioners are consulting firms specialising in construction-sector LCA, though some larger manufacturers maintain in-house capability.

When selecting a practitioner, consider their experience with your product type, their familiarity with the applicable PCR, the LCA software they use (common tools include GaBi, SimaPro, and openLCA), and their track record of producing EPDs that pass third-party verification on the first attempt. A practitioner experienced with the applicable PCR will save time and reduce the risk of methodological errors that cause verification delays.

Gathering Production Data

The LCA practitioner will request detailed production data from you. This typically includes:

Data Category Details Required
Energy consumption By type: electricity, natural gas, fuel oil, biomass
Raw-material inputs Types, quantities, and sources
Transport Distances and modes for incoming materials
Water Consumption volumes
Emissions Direct emissions to air and water (if measured)
Waste Generation by type and disposal route
Production volumes Annual output for reference period
Typical data requirements for an LCA study

Data quality matters: Data should cover a representative period (usually one full calendar year). The PCR may require at least 95% of mass and energy inputs to be accounted for, and data must be no older than five years.

If specific data is unavailable, the practitioner may use conservative proxy data from recognised databases, but primary data is always preferred.

LCA Modelling and Reporting

The practitioner builds a life-cycle model in their software, populating foreground processes with your specific data and background processes with data from databases such as ecoinvent or GaBi Professional. They calculate all mandatory environmental impact indicators per the declared or functional unit across all required life-cycle modules. The results are compiled in an LCA report, also called a project report or background report, which documents the methodology, data sources, assumptions, allocation rules, and sensitivity analyses. This report is a critical document for verification.

Step 4: Draft the EPD Document

Content and Format

The EPD document itself is distinct from the LCA report. It is the public-facing declaration that will be registered with the programme operator and accessed by specifiers, procurement officers, and project teams. Its content follows a standardised format defined by EN 15804+A2 and the programme operator’s general programme instructions.

A typical EPD includes the following sections: general information about the product and manufacturer; a description of the product, including its composition and packaging; information about the LCA study, including system boundaries, data quality, and cut-off rules; environmental impact indicators for each declared life-cycle module; resource use indicators; waste categories and output flows; scenario descriptions for transport, installation, use, maintenance, and end-of-life stages (where applicable); and information about the verification, including the verifier’s name and the date of verification.

Many programme operators provide EPD templates to ensure consistency across their registry. EPD Polska provides templates that comply with EN 15804+A2 and its general programme instructions, making the drafting process more straightforward.

Step 5: Third-Party Verification

Why Verification Matters

Third-party verification is what distinguishes an EPD from a self-declaration. An independent verifier, appointed or accredited by the programme operator, reviews both the LCA study and the EPD document to confirm that they comply with ISO 14025, EN 15804+A2, and the applicable PCR. The verifier checks the methodology, the data quality, the calculations, the consistency between the LCA report and the EPD document, and the completeness of reporting.

Third-party verification is what distinguishes an EPD from a self-declaration.

The Verification Process

Verification typically involves a desk review of the LCA report and the EPD document, followed by one or more rounds of comments and responses. The verifier may raise questions about data sources, allocation choices, scenario assumptions, or the presentation of results. The LCA practitioner responds to these queries, makes corrections as needed, and resubmits. Once the verifier is satisfied that all requirements are met, they issue a verification statement confirming that the EPD is compliant.

The verification process can take anywhere from two weeks to two months, depending on the complexity of the product, the quality of the initial submission, and the verifier’s workload. Choosing an experienced LCA practitioner who is familiar with the verifier’s expectations can significantly reduce the number of review cycles needed.

Step 6: Register the EPD with the Programme Operator

Publication and Visibility

Once verification is complete, the manufacturer submits the verified EPD to the programme operator for registration. EPD Polska reviews the submission for completeness, assigns a registration number, and publishes the EPD on its registry. The registration date marks the start of the EPD’s validity period, which is typically five years.

EPDs registered with EPD Polska are also listed on EPDportal.org, providing international visibility to architects, engineers, and procurement teams worldwide. This dual presence, on the national programme operator’s registry and on an international showcase platform, maximises the commercial value of the EPD investment.

Timeline and Costs

Typical Timeline

The entire process from initial scoping to published EPD typically takes three to six months. The breakdown is roughly as follows:

  1. Scoping and PCR identification. 1–2 weeks to define product scope and locate the applicable PCR.
  2. Data collection. 2–4 weeks (depends heavily on the manufacturer’s data readiness).
  3. LCA modelling and reporting. 4–8 weeks for the practitioner to build the model and compile the LCA report.
  4. EPD drafting. 1–2 weeks to prepare the public-facing EPD document.
  5. Third-party verification. 2–6 weeks for independent review, comments, and corrections.
  6. Registration and publication. 1–2 weeks for final review and publication by the programme operator.

The biggest variable is data collection. Manufacturers who have well-organised production data, energy records, and material inventories can compress the timeline significantly.

Typical Costs

€2k–8k
typical total cost for a single-product, single-site EPD (LCA + drafting + verification + registration)

Costs vary depending on the product complexity, the scope of the EPD, and the practitioner’s fees. For a single-product, single-site EPD, total costs typically range from approximately two thousand to eight thousand euros. This covers the LCA study, EPD drafting, verification fees, and programme operator registration fees. Multi-product or multi-site EPDs may cost more due to the additional data collection and modelling effort. Some programme operators offer reduced fees for small and medium-sized enterprises or for manufacturers registering multiple EPDs simultaneously.

Practical Tips for a Smooth Process

Pro tip: Appoint an internal project lead who understands the production process and can coordinate data collection across departments. Ensure energy invoices, raw-material purchase records, and waste disposal documentation are readily accessible and cover at least one full year.

Several practical measures can help manufacturers navigate the EPD process efficiently. Communicate with the LCA practitioner early about any unusual production processes, multi-output situations, or data gaps, so that solutions can be planned before modelling begins. Request a preliminary review of the LCA results before the EPD is drafted, to catch any unexpected outcomes. And finally, build in buffer time for the verification step, particularly if this is your first EPD and the product system is complex.

What Happens After Publication?

An EPD is not a one-time exercise. Over its five-year validity, the manufacturer should monitor whether production conditions change significantly enough to warrant an update. Major changes in energy sources, raw-material suppliers, or manufacturing processes may affect the accuracy of the declared values. Some programme operators allow voluntary updates without full re-verification, while others require a new verification cycle for material changes. At the end of the five-year period, a renewal involves an updated LCA and a new verification, following the same six-step process.

Looking ahead, the LCA landscape for construction products continues to evolve with regulatory developments and methodological updates. Manufacturers who have been through the EPD process once will find renewals and extensions significantly easier, having already built the data infrastructure and institutional knowledge needed to produce high-quality environmental declarations.

Frequently Asked Questions

Can I prepare the LCA myself or do I need an external practitioner?

There is no formal requirement to use an external LCA practitioner. If your organisation has qualified personnel with expertise in ISO 14040, ISO 14044, EN 15804+A2, and the applicable PCR, you can perform the LCA in-house. However, the EPD must still undergo independent third-party verification, so the verifier will scrutinise the study regardless of who performed it. Many manufacturers find that engaging an experienced external practitioner reduces risk and accelerates the process.

How do I choose between different programme operators?

Consider the programme operator’s PCR coverage for your product category, the geographic reach of their registry, their fees, and their support services. For manufacturers based in Poland and Central-Eastern Europe, EPD Polska offers comprehensive PCR coverage, bilingual support in Polish and English, and international visibility through EPDportal.org. The key is to select an operator whose PCR library covers your product and whose registration process aligns with your timeline.

What data do I need to provide for the LCA?

At minimum, you will need annual energy consumption data broken down by energy carrier, a bill of materials for your product (raw-material types and quantities), transport distances and modes for incoming materials, water consumption, waste generation data, and production volumes. Direct emissions data, if available from monitoring or permits, is also valuable. The more complete and accurate your data, the more representative and credible the resulting EPD will be.

Can I use an EPD from one country in another country’s market?

Yes, EPDs are designed for international use. An EPD registered with EPD Polska and complying with EN 15804+A2 and ISO 14025 is recognised across Europe and in many markets worldwide. Green building rating systems such as BREEAM and LEED accept EPDs from recognised programme operators regardless of the country of registration. The international showcase on EPDportal.org further enhances cross-border visibility.

What if my product already has a carbon footprint study?

A carbon footprint study can serve as a useful starting point, but it is generally not sufficient for an EPD. An EPD requires a full life-cycle assessment covering all mandatory impact indicators under EN 15804+A2, not just GWP. Additionally, the LCA must comply with the applicable PCR, use the prescribed characterisation factors, and follow the specific allocation and reporting rules of the standard. An existing carbon footprint study can reduce data-collection effort for the GWP component, but additional modelling will be needed for the other indicators and for compliance with the PCR.