It is the question we hear most often: should we do an EPD, or a product carbon footprint? The two are related — both are independently verified, both are based on life-cycle assessment — but they answer different questions and are driven by different rules. In practice, two questions settle almost every case: is it a construction product? and what is your buyer actually asking for?
The two questions that decide it
1. Is it a construction product? If yes — and you sell into the EU, into tenders, or into green-building schemes — an EPD is the expected document. If it is not a construction product, a carbon footprint is usually the more natural fit.
2. What does your buyer ask for? If they want a full environmental profile, or specifically an EPD, you need an EPD. If they want a single carbon figure — kilograms of CO2 per unit, or supplier data for their own Scope 3 reporting — a product carbon footprint is faster and cheaper.
EPD — when it is the right choice
An Environmental Product Declaration reports many environmental indicators (climate, acidification, eutrophication, water and resource use, and more) to EN 15804+A2 and ISO 14025. It is the established standard for construction products — concrete, cement, steel, insulation, windows, aggregates, membranes. Choose an EPD when:
- your product is a building material and you sell into construction;
- buyers, architects or tenders ask for an EPD, or for BREEAM, LEED or DGNB points;
- you need a full environmental profile, not just the carbon number;
- you are preparing for the Construction Products Regulation, which moves construction products towards mandatory environmental declarations based on EN 15804.
Product carbon footprint — when it is the right choice
A product carbon footprint focuses on one thing — climate — and reports a single verified figure in kg CO2e per declared unit, to ISO 14067. Choose a carbon footprint when:
- your product is not a construction product (packaging, food and agri, consumer goods, industrial products, chemicals);
- your customer asks for a carbon figure, or for supplier data for their value-chain (Scope 3) reporting under the CSRD;
- you want the fastest, lowest-cost way to give buyers credible, verified carbon data;
- climate is the indicator that matters to your market right now.
The decision in one table
| Your situation | Best fit |
|---|---|
| Construction product; EU sales, tenders, BREEAM/LEED/DGNB | EPD |
| Non-construction product (packaging, food, industrial, consumer) | Carbon footprint |
| Buyer asks for a CO2 figure or Scope 3 / CSRD data | Carbon footprint |
| You need a full environmental profile, not only carbon | EPD |
| Fastest, lowest-cost entry; climate is what matters | Carbon footprint (upgrade to EPD later) |
What the law actually requires
Legal drivers, not preference, often make the decision:
| Regulation | What it drives | Document |
|---|---|---|
| Construction Products Regulation (CPR, 2024/3110) | Environmental declarations for construction products, based on EN 15804, within the Digital Product Passport | EPD |
| CSRD (corporate sustainability reporting) | Scope 3 reporting — companies need verified carbon data from suppliers | Carbon footprint |
| ESPR / Digital Product Passport | Product-level environmental and carbon data across many categories | Both; carbon central |
| CBAM | Carbon content of certain imports (cement, steel, aluminium, fertilisers, hydrogen) | Separate regime — see note |
| Green Claims / Empowering Consumers | Substantiation of environmental marketing claims | PEF or carbon footprint |
An important caution: CBAM is not the same as an EPD or a product carbon footprint. CBAM uses its own methodology and accredited verifiers under the EU emissions-trading regime. A voluntary EPD or carbon footprint is valuable for B2B and CSRD, but it is not a CBAM declaration.
PEF and carbon footprint — European and international
A frequent point of confusion is the relationship between the Product Environmental Footprint (PEF) and the carbon footprint. They sit on two different axes — who issued the method, and how broad it is.
| Carbon footprint (ISO 14067) | PEF | EPD (EN 15804) | |
|---|---|---|---|
| Issued by | ISO (international) | European Commission (EU) | EN + ISO |
| Scope | Climate only | Multi-indicator (16) | Multi-indicator |
| Category rules | CFP-PCR / PCR | PEFCR | PCR / c-PCR |
| Mainly used for | B2B carbon, Scope 3, exports | EU consumer-facing claims | Construction, tenders |
In short: the carbon footprint (ISO 14067) is an international, climate-only standard; PEF is a European, multi-indicator method tied to EU consumer-claims policy. For most B2B and construction work today, EPD and the carbon footprint are the practical choices; PEF becomes relevant when a company makes public environmental claims to consumers, and its category rules (PEFCR) do not yet exist for every product.
A practical path
For many manufacturers the answer is not either/or but a sequence. A product carbon footprint is a low-barrier first step that satisfies a buyer’s immediate carbon request; a full EPD follows when you enter construction, win the kind of tenders that require it, or need a multi-indicator profile. Both are prepared and independently verified under the same EPD Polska programme, so the work you do for one feeds the other.
Not sure which applies to your product? Tell us what you make and who is asking, and we will confirm the right route and a quote — scoping is free.