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Guidance on interpretation of programme instructions

Sometimes the programme instructions are difficult to interpret in terms of some of its requirements and recommendations. Guidance on the use is provided by the Technical Committee, and is incorporated into future versions of the document.

In the meantime, this guidance is available on this page.

Procedure for developing EPDs of products not yet on the market 

There is a potential demand for the development of EPDs for products that are designed and planned for future marketing, although they are not yet available on the market. This may occur, for example, in public procurement when companies are requested to provide customized versions of their standard range of products. The development of such EPDs poses the following compliance issues with the GPI:

  • Since these products are not yet manufactured, the declaration of the reference year of production (§9.5.3 Product Information) may not be available,
  • The lack of specific data related to manufacturing processes may make the system model not in line with the data quality requirements established for the application of the LCA methodology (A.5.2)

It was decided by the Technical Committee to adopt the following procedure to overcome these issues.

Procedure for developing EPDs of products not yet on the market
Products designed and planned but not yet launched on the market (forthcoming products) may be included in an EPD provided that the EPD owner has a validated LCA model for a similar product (as defined in §9.3.1) and the latter is compliant with the GPI and the applicable PCR (e.g. a registered EPD for a similar product is available).

Moreover, a similar product is defined as a sibling product when its LCA model is equal to the one of the forthcoming product in terms of data composition. The only differences regard the activity data (e.g. a different material or packaging composition share, a different energy consumption in the manufacturing process, a different distribution distance).

If the environmental profile of the forthcoming product is built based on a sibling product, the data quality requirements in A5.2 of the GPI are assumed to be fulfilled.

Table 1 provides a fictious example of sibling products association. The text in bold represents the sensitive data to be addressed in the application of the procedure.

When differences between products are not limited to activity data but involve changes in the LCA model, e.g. use of different materials in product assembly or the use of a different manufacturing technology, a similar product is defined a non-sibling product.

In this case, the LCA model of the forthcoming product may be equally built based on the similar product, but the EPD owner shall prove that data quality requirements in A5.2 are met. In such case, the EPD owner is allowed to use available inventory data for comparable technologies existing on the market (e.g. data from competitors or other manufacturers) and qualify them as specific data.

Forthcoming products may be then presented in an EPD using the impact of a similar product (either sibling or non-sibling) or through separate results depending on the provision in §9.3.1 of the GPI.

EPDs for forthcoming products shall contain in the product description section the following disclaimer:

  • Product not yet on the market

Verification of forthcoming products shall be carried out in accordance with the principles and procedures in Section 7.

The environmental profiles of forthcoming products shall be updated and re-verified after 1 year of actual production.

In both cases, regardless of the association to a sibling or non-sibling product, the presentation of the environmental profiles in EPD follows the provision in §9.3.1 of the GPI.


Clarification regarding indicators for use of resources and waste

These indicators account for resource used and waste produced along the whole life cycle of the declared product (upstream, core and downstream processes). They are the result of the Life Cycle Inventory, and represent net flows of resources and waste crossing the system boundaries. See Figure 1 below.

Please note that the amount of wastes and the destination shall be declared as outflows from the system only when the waste treatment process is not included within the system boundaries.

Also note that some aggregated generic LCI datasets, most notably those from the Ecoinvent database, include all waste treatment processes within the system boundaries, i.e. there are no waste flows exiting the system boundaries and the waste indicators to be declared will be zero. In contrast, other aggregated generic LCI datasets, such as Gabi datasets, often have waste flows exiting the system boundaries, and the waste indicators to be declared will therefore be non-zero.

 Image explaining indicators for resource use and waste

Figure1  Illustration that indicators for use of resources, environmental impacts and wastes all concern the whole life cycle, and those flows that leave the system boundaries.


Clarification regarding the use of normalization within EPDs

As some stakeholders may be interested in the use of normalization in EPDs, here we clarify the position of the International EPD System with regards to normalization: the results of normalization are not allowed to be reported in an EPD. Below we explain the reasoning behind this position.

ISO 14044:2006 § defines normalization as:

Normalization is the calculation of the magnitude of the category indicator results relative to some reference information.

The aim of the normalization is to understand better the relative magnitude for each indicator result of the product system under study. It is an optional element that may be helpful in, for example,

  • checking for inconsistencies,
  • providing and communicating information on the relative significance of the indicator results, and
  • preparing for additional procedures, such as grouping, weighting or life cycle interpretation

Normalization transforms an indicator result by dividing it by a selected reference value. Some examples of reference values are:

  • the total inputs and outputs for a given area that may be global, regional, national or local,
  • the total inputs and outputs for a given area on a per capita basis or similar measurement, and
  • inputs and outputs in a baseline scenario, such as a given alternative product system.

The selection of the reference system should consider the consistency of the spatial and temporal scales of the environmental mechanism and the reference value.

The normalization of the indicator results can change the conclusions drawn from the LCIA phase. It may be desirable to use several reference systems to show the consequence on the outcome of mandatory elements of the LCIA phase. A sensitivity analysis may provide additional information about the choice of reference data. The collection of normalized category indicator results represents a normalized LCIA profile.

According the General Programme instrucvtion, v. 3.01, the content and format of EPD have to follow these requirements:

  • shall be in line with the requirements and guidelines in ISO 14020 (Environmental labels and declarations - General principles),
  • shall be verifiable, accurate, relevant, and not misleading, and
  • shall not include rating, judgements, or direct comparisons with other products.

Normalization may be compliant with the first two requirements, but not with the third.

The methodology for transforming an indicator result by dividing it by a selected reference value introduces a rating that may be misleading and arbitrary.

Normalization may be a powerful and useful instrument inside an LCA study but its results cannot be reported in an EPD.