Introduction: Most Guides Tell You How to Make an EPD. Almost None Tell You How to Judge One.
An Environmental Product Declaration is only as good as its weakest assumption. Here are the seven things an experienced verifier checks first — and any one of them, unanswered, is a reason to reject the EPD.
Specifiers, contractors and procurement teams increasingly receive EPDs from suppliers and take the carbon number at face value. They should not. An EPD is a structured document with rules (ISO 14025 and, for construction products, EN 15804), and a weak or misused EPD can quietly distort a tender or a whole-life-carbon calculation. This guide shows you how to read one the way a verifier does.
The Seven Red Flags
1. No named, independent verifier or programme operator
Under ISO 14025, a Type III declaration must be independently verified and published under a programme. If you cannot find the verifier’s name, the programme operator, and a registration number, treat the document as a self-declaration, not an EPD.
2. Expired — or about to expire
EPDs are typically valid for five years. A specification that cites an expired EPD is citing data the manufacturer no longer stands behind. Check the issue and expiry dates first; an EPD in its final months is a planning risk.
3. No PCR reference (or the wrong one)
Every credible EPD names the Product Category Rules it follows. Without the governing PCR, the results are not comparable and the methodology is unauditable. Two EPDs built on different PCRs are not directly comparable, however similar the products.
4. A mislabelled system boundary
A cradle-to-gate EPD covers modules A1–A3 only. If a document presents A1–A3 numbers but talks as though they are “cradle to grave,” the boundary is being oversold. Confirm exactly which life-cycle modules are declared before you compare anything.
5. A single “GWP” with no breakdown
Under EN 15804+A2, global warming potential must be reported split into GWP-fossil, GWP-biogenic and GWP-luluc, plus GWP-total. A lone “GWP” figure with no split is either an older (+A1) format or an incomplete declaration — and it can hide a large biogenic or land-use component.
6. Unstated or non-representative data
Is it a manufacturer-specific EPD or an industry average? From which plants, which years, which country? Old, geographically mismatched, or averaged data can misrepresent the specific product you are buying. A credible EPD states its data quality, representativeness and reference period plainly.
7. Offset or “carbon-neutral” claims bolted on
An EPD reports impacts; it does not certify neutrality. If a declaration is wrapped in “carbon-neutral” or offset language, that is a marketing claim layered on top — and, increasingly, one the EU’s green-claims rules will scrutinise. Read the verified indicators, not the cover slogan.
How to Use This in Practice
You do not need to be a verifier to apply these checks. Ask the supplier for: the programme and registration number, the PCR, the declared modules, the +A2 GWP breakdown, the data type and reference year, and the validity dates. If any are missing, ask again — or discount the EPD in your evaluation. The same scrutiny that protects your tender also tells you which suppliers genuinely have their data in order (the ones who will also be ready for CBAM).
How EPD Polska / Multicert Can Help
We prepare and independently verify EPDs to EN 15804 / ISO 14025, and we help buyers assess third-party EPDs before they rely on them. If you need an EPD reviewed or produced properly, contact us.
FAQ
Can I compare two EPDs directly?
Only if they follow the same PCR, declare the same life-cycle modules, and use the same EN 15804 version. Otherwise the comparison is misleading.
Is an unverified EPD worth anything?
It is a self-declaration, not a Type III EPD. For tenders and green-building credits, independent verification under a programme is what counts.
What does the +A2 GWP split tell me?
It separates fossil, biogenic and land-use carbon, so you can see what is really driving the number — essential for timber, bio-based and recycled-content products.