Mandatory Annual Internal Follow-Up to Ensure EPD Compliance

11 December 2025 | EPD
The establishment and implementation of an Internal Follow-Up Procedure is a mandatory requirement for all published and valid EPDs. The process ensures the information presented in the EPDs are up-to-date.

The Secretariat of the International EPD System highlights the mandatory requirement for all EPD owners to establish and implement an internal Follow-Up at least once per year following the publication of an Environmental Product Declaration (EPD), as outlined in GPI 5.0.1, Sections 6.8.1, 8.3.2, and 8.4.8.

This procedure, under full responsibility of the EPD Owner, as in accordance with GPI 5.0.1 section 4.2.2, ensures that all information and data presented in an EPD remain up to date throughout its five-year validity period.

Outcomes from the internal follow-up procedure may necessitate an update and re-verification of the reviewed EPD. An EPD shall be updated and re-verified during its validity if there are errors in the declared information, or if changes in technology or other circumstances have led to:

  • an increase of 10% or more in the aggregated results over included life-cycle stages for any of the declared environmental performance indicators

  • substantial changes to the declared product information (e.g., change of manufacturing site, change of lifespan, products added in EPD of multiple products), content declaration (e.g., new materials/substances, changed composition), or additional environmental, social, or economic information

Additional examples of relevant changes include significant updates to applied datasets, changes to underlying data and information retrieved from suppliers, updates of EPDs used as a data source, or the release of more representative datasets applicable to the product system. 

Follow-up activities must be performed at least annually, based on the last version date, and with sufficient frequency to capture any significant developments. This process is essential to maintaining the reliability, transparency, and integrity of all EPDs published in the International EPD System.

EPD internal follow-up report on EPD Templates is an example template to support EPD owners in conducting the internal follow-up and monitoring changes. EPD owners may alternatively use their own format, provided that the internal follow-up report thoroughly documents all relevant information and changes.

For more information on updating requirements and detailed guidance, visit our FAQ on Internal Follow-up Procedure.

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