Question 1

What is EPD verification?

Accepted Answer

EPD verification is a mandatory independent review of an EPD before it can be published. A qualified third-party verifier checks that the LCA model, data, assumptions and report comply with the relevant PCR and EN 15804+A2.

Question 2

How long does EPD verification take?

Accepted Answer

Typically 2–4 weeks, depending on the complexity of the product and the completeness of the documentation submitted. From the verifier’s chair, incomplete data documentation is the single biggest cause of delay — a complete first submission removes whole rounds of Q&A.

Question 3

What is the difference between EPD preparation and EPD verification?

Accepted Answer

EPD preparation involves conducting the LCA and writing the EPD report. EPD verification is the independent review of that report by a qualified third party before publication. EPDlogy offers both — but never for the same project, to preserve verifier independence.

Question 4

Which EPD programmes do you verify for?

Accepted Answer

We are an approved verifier on four international EPD programmes, including The International EPD® System.

Question 5

What is an EPD (Environmental Product Declaration)?

Accepted Answer

An EPD is a Type III environmental declaration under ISO 14025: an independently verified report of a product’s environmental performance across its life cycle. It is based on an LCA compliant with ISO 14040/44; for construction products, EN 15804+A2 and the relevant PCR apply. The declaration is published by a programme operator and is publicly available. See our article What is an EPD? for the full picture.

Question 6

How do I get an EPD — what does the process look like?

Accepted Answer

The usual sequence: define the product scope and select the right PCR → collect data (production, energy, transport, waste, precursor materials) → build the LCA model to EN 15804+A2 and PCR rules → draft the EPD report → independent verification → publication by the programme operator. Data collection is usually the longest step; with a prepared manufacturer the whole process takes a few months. Our EPD preparation service manages it end to end.

Question 7

How long is an EPD valid?

Accepted Answer

EPDs are generally valid for five years. If production processes, energy sources or input materials change in a way that meaningfully affects the environmental results, an update is needed before expiry. The most common miss in practice: a recipe or supplier change assumed to be “minor” and never reflected in the EPD.

Question 8

Is an EPD mandatory?

Accepted Answer

There is no single rule requiring every product to carry an EPD — but the mandatory space is growing fast. The new EU Construction Products Regulation (CPR, 2024/3110) brings life-cycle-based environmental performance into the declaration system, phased in per product group. Green building schemes (LEED, BREEAM) and public procurement also make EPDs a de facto requirement. Our advice to exporting manufacturers: don’t wait for your category to be scheduled — build the data infrastructure now.

Question 9

What is the difference between an EPD and a carbon footprint?

Accepted Answer

A carbon footprint covers one indicator (greenhouse gas impact). An EPD reports all impact categories and resource indicators defined by the PCR, in defined life-cycle modules (A1–A3, C, D…), and is independently verified. In short: an EPD is a broader, rule-bound declaration that includes the carbon footprint.

Question 10

What is a PCR, and why does it come before the standard?

Accepted Answer

Standards have to be written generically, to fit every product. Product Category Rules (PCR) narrow the choices the standard leaves open for a specific product category: the declared unit, the system boundaries, which scenarios to use, which additional indicators to report. The practical consequence: starting the LCA before selecting the PCR can mean recalculating later. One of the most frequent returns we see from the verifier’s chair is a study built on the wrong or an outdated PCR. Choose the programme operator and the PCR at the start of the project.

Question 11

When exactly does an EPD need updating or re-verification?

Accepted Answer

A common point of confusion — let’s separate three layers. What the standard says: EN 15804 requires the EPD to be re-evaluated and updated as necessary to reflect changes in technology or other circumstances that could affect the content and accuracy of the declaration — with no numerical threshold in that sentence. The threshold used in practice: most programme operators treat a change exceeding ±10% in the A1–A3 GWP-total result as a “significant change” requiring re-verification; typical triggers are changes in process equipment, raw materials or the energy source. The new development: EN ISO 14025:2026 asks programme operators to define re-evaluation and update procedures and to determine what counts as a “significant change”, giving an increase of at least 10% in a declared indicator as a guiding example; a task group within ECO Platform is also working on a common interpretation of the ±10% rule. Bottom line: the threshold comes from your programme operator’s rules, not from the standard itself — check your operator’s procedure; some changes require re-verification while others may only need re-approval.

Question 12

Can several products be declared in a single EPD?

Accepted Answer

Yes, but conditionally. For products from the same manufacturing site with limited differences, three common approaches exist: the average product (an average across the products is calculated and declared), the representative product (the product making up most of the production is selected, with the justification stated in the EPD) and the worst case (the highest value is taken for each indicator). Under the first two, the grouped products’ results are expected to stay within a certain range — in practice usually taken as ±10%. The second limiting factor is readability: too many result tables or scaling factors make the document unusable for the designer relying on it. Sometimes publishing several EPDs from the same study is the better answer.

Question 13

Cradle-to-gate or cradle-to-grave — which scope do I need?

Accepted Answer

Three common scopes: cradle-to-gate (A1–A3: raw material supply, transport and manufacturing), cradle-to-gate with options (A1–A3 plus selected additional modules) and cradle-to-grave (the full life cycle including use and end of life). Which scope is needed is usually determined by whoever is asking for the EPD. For a customer running building-level life-cycle calculations, an EPD with only A1–A3 often falls short — the building calculation cannot be completed without modules C and D. Extending the scope later costs more than setting the study up broadly from the start.

Question 14

What is the background report, and how does it differ from the EPD?

Accepted Answer

The background report (project report) is the document prepared so the verifier can examine the data sources, assumptions, modelling decisions and PCR compliance. It is not published; it is used only in the verification process. The EPD is the public, summarised, rule-bound output of that work. The biggest cause of lost time in verification is an incomplete background report — if modelling decisions are not documented, the verifier has to ask about every item separately.

Question 15

What does the choice of programme operator change?

Accepted Answer

The standard requirements do not change by operator. What changes: the applicable PCR and its level of detail, the verifier approval and acceptance process, publication and update fees, validity and renewal procedures, which databases the declaration appears in, and whether it is provided in machine-readable format. Asking upfront which operators are recognised in your target market and which databases your customers pull data from protects you from the cost of preparing a second EPD later.

Question 16

Can private-label products get an EPD?

Accepted Answer

Usually yes. Where an EPD has been published in the name of the original manufacturer, a private-label EPD based on the same study can be published. In practice these declarations share the validity date of the original EPD. Conditions and fees vary by programme operator.

Question 17

Can the mass balance approach be used in an EPD?

Accepted Answer

Not at present. The mass balance approach means allocating raw material flows with specific characteristics (recycled content, bio-based material) to products on a theoretical rather than a physical basis. This method is not accepted in EPDs; the topic continues to be discussed within CEN/TC 350 WG3 and ECO Platform. The practical consequence: recycled-content percentages communicated in marketing on a mass-balance basis cannot be declared the same way in an EPD.

Question 18

What product types can you verify?

Accepted Answer

Steel, aluminium, concrete, insulation, facade systems, windows, flooring, ceiling systems, furniture, plastics, paints and more. Experience across a wide range of construction product categories.

Question 19

What standards do you work with?

Accepted Answer

EN 15804+A2, ISO 14025, ISO 14040/44 and ISO 21930, together with the relevant PCR documents and programme operator instructions.

Question 20

Can you work with manufacturers outside Europe?

Accepted Answer

Yes. EPDlogy works with manufacturers across Türkiye, Europe, Asia and the Americas. All services are provided remotely.

Question 21

Will the Digital Product Passport (DPP) affect EPDs?

Accepted Answer

Yes — the direction is clear. The new Construction Products Regulation establishes the legal basis for a digital product passport for construction products, with details to follow in secondary legislation. Product environmental data is moving from static PDFs to structured, machine-readable data. A well-built LCA data infrastructure today is the content of tomorrow’s passport. More in our article: What is the Digital Product Passport?

Question 22

How do I get started?

Accepted Answer

Use the contact form or send an enquiry directly to ipek@epdlogy.com. Include your product type, target EPD programme and preferred timeline.

Question 23

What is CBAM?

Accepted Answer

The Carbon Border Adjustment Mechanism (CBAM) puts a carbon cost on the embedded emissions of carbon-intensive goods imported into the EU, equivalent to what EU producers pay under the EU ETS. Its purpose is to prevent carbon leakage. Sectors in scope: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen.

Question 24

Where are we in the CBAM timeline?

Accepted Answer

The transitional period (1 October 2023 – 31 December 2025) was reporting-only. The definitive period started on 1 January 2026 and now carries financial consequences. The first annual CBAM declaration, for 2026, is due by 30 September 2027. The Commission also published its verification and accreditation guidance in August 2026 — summarised in our news section.

Question 25

Who carries the CBAM obligation: the EU importer or the non-EU producer?

Accepted Answer

The legal obligation sits with the EU-established importer (the authorised CBAM declarant) or the indirect customs representative. But the product-, installation- and period-level emissions data behind the declaration must come from the producer. In practice the obligation travels down the contract: a supplier that cannot deliver data becomes a cost and a risk for its buyer. “We have no obligation” is legally true and commercially misleading.

Question 26

Is using default values good enough?

Accepted Answer

Where actual data is not available, the Commission’s default values can be used — but they carry an increasing mark-up: 10 % in 2026, 20 % in 2027, 30 % in 2028 (a flat 1 % for fertilisers). For most producers that means a visibly higher cost than actual data. You can query current values by country and product free of charge in our CBAM Default Values tool.

Question 27

What data do we need to prepare for CBAM?

Accepted Answer

A corporate carbon footprint is not enough here. You need embedded emissions broken down by product (CN code), installation and reporting period: direct emissions, indirect emissions where applicable, precursor emissions, production route, and records of any carbon price actually paid in a third country. In our experience the two items producers struggle with most are precursor data and electricity data. The calculation must be traceable and verifiable.

Question 28

We have an EPD — can it be used for CBAM?

Accepted Answer

Not directly: CBAM has its own system boundary and calculation rules, which do not map one-to-one onto the EN 15804 module structure. But the installation-level energy, material and process data infrastructure built for an EPD is also the foundation of a CBAM calculation. Building one shared data base instead of two parallel exercises lowers cost and improves consistency — that is how we set up our projects.

Question 29

Does the 50-tonne exemption take us out of scope?

Accepted Answer

Under the EU simplification package, EU importers bringing in less than 50 tonnes per year of covered goods are exempt from CBAM obligations. The threshold applies per importer; if exceeded during the year, all of that year’s imports fall back in scope, and electricity and hydrogen are excluded from the exemption. For a non-EU producer the practical answer is: the exemption belongs to your buyer, not to you — a producer with several customers can rarely avoid data preparation.

Question 30

What does EPDlogy do on the CBAM side?

Accepted Answer

An accredited CBAM verification report must be issued by a verifier accredited under the applicable CBAM rules; EPDlogy works on the preceding verification-readiness stage: structuring installation data to CBAM rules, setting up the embedded emissions calculation, reviewing monitoring documentation through a verifier’s lens, and comparing default values against actual data. Free resources: our CBAM Default Values tool and the official guidance archive.

Question 31

Who does the 50-tonne exemption cover?

Accepted Answer

EU importers whose annual CBAM imports stay below a 50-tonne mass threshold are exempt from the authorisation requirement; hydrogen and electricity fall outside the exemption. The threshold works per importer, not per product — virtually every ongoing supply relationship sits above it. Details in our CBAM timeline article.

Question 32

How is the CBAM certificate price set?

Accepted Answer

The European Commission calculates and publishes it as the weighted average of EU ETS auction clearing prices. Quarterly in 2026 (Q3 2026: €82.32/tCO₂e), weekly from 2027. We keep the current figures on our certificate price page.

Question 33

Is a carbon price paid in my country deducted from CBAM?

Accepted Answer

Article 9 of the Regulation allows for it, under narrow conditions: the price must have been effectively paid (rebated amounts do not count), only compliance schemes are considered (voluntary markets are not), and the assessment is made country by country by the European Commission. Emissions covered by free allocation carry no effective payment. Details in our Article 9 article.

Question 34

How high are CBAM penalties?

Accepted Answer

For an authorised declarant failing to surrender certificates, the penalty is tied to the EU ETS excess emissions penalty: a base of €100 per tonne of CO₂e, increased with the European index of consumer prices from 2013 onwards. Unauthorised imports carry 3-5 times that amount. The penalty always lands on the EU importer. Details and legal bases on our penalties page.

Question 35

Does the UK have a CBAM too?

Accepted Answer

Yes — the UK CBAM starts on 1 January 2027 with a different design: a levy instead of certificates, a £50,000 value threshold instead of 50 tonnes, and electricity out of scope. Producers exporting to the UK as well will be preparing data for two regimes from 2027. Comparison in our UK CBAM article.

Question 36

What is Türkiye’s Climate Law?

Accepted Answer

Climate Law No. 7552 entered into force on 9 July 2025. It establishes the legal basis for carbon pricing in Türkiye in line with the 2053 net-zero target, including the Türkiye Emissions Trading System (TR ETS). For industrial installations this is not a distant topic: the pilot phase starts with the CBAM sectors.

Question 37

When does the Türkiye ETS start, and who is covered?

Accepted Answer

The Türkiye Emissions Trading System Regulation was published in the Official Gazette on 27 August 2026 (No 33353) and entered into force, repealing the 2014 GHG monitoring regulation. The system covers category B installations (50,000–500,000 t CO₂e/year) and category C installations (above 500,000 t) carrying out Annex-1 activities; covered installations need a five-year GHG emission permit from the Climate Change Directorate to continue operating. Under Carbon Market Board decision KPK/2026/1, the pilot phase covers 2026 and 2027 emissions and includes category B and C installations in electricity generation, cement, iron & steel, aluminium and fertilisers; the current status is worth tracking via iklim.gov.tr. On the verification side, the Regulation makes verification of the emissions report mandatory before submission and requires verifiers to be accredited by TÜRKAK against ISO/IEC 17029; verifiers are assigned through the central electronic assignment system (MEDAS), not chosen directly by the operator.

Question 38

Will the TR ETS reduce our CBAM cost?

Accepted Answer

The logic: a carbon price actually paid in the country of production can be deducted from the CBAM obligation, so carbon costs paid in Türkiye are not paid a second time at the EU border. This is one of the reasons TR ETS is being built. The documentation side needs care, though: the payment must be traceably linked to the installation and the product. One more nuance: under the Regulation, free allocation is calculated against a benchmark value, not the installation’s realised emissions — even at a 100% free-allocation rate, an installation whose emissions intensity sits above the benchmark can run a deficit. The numerical benchmark values have not yet been published.

Question 39

Is sustainability reporting mandatory in Türkiye?

Accepted Answer

For certain companies, yes. Companies in scope of the Türkiye Sustainability Reporting Standards (TSRS, aligned with ISSB S1/S2) must report. Thresholds were updated by the public oversight authority (KGK) in January 2026: total assets TRY 1 billion, net sales TRY 2 billion, 500 employees — at least two of the three criteria exceeded in two consecutive reporting periods (for periods beginning on or after 1 January 2025). Banks, listed companies and insurers are in scope regardless of size.

Question 40

Corporate vs product carbon footprint — what is the difference?

Accepted Answer

A corporate carbon footprint (ISO 14064-1) reports an organisation’s annual emissions within its organisational boundary as Scopes 1–3. A product carbon footprint (ISO 14067) quantifies the life-cycle impact of a single product using LCA. Customers and tenders increasingly ask for the product-level view — which is where EPDlogy works: product-level LCA, EPD and CBAM data.

Question 41

Is verification of a carbon footprint mandatory?

Accepted Answer

Not for a stand-alone voluntary calculation. But once the report becomes part of an obligation, the picture changes: TSRS reports are subject to assurance, installations under an ETS face mandatory MRV, and CBAM requires accredited verification for actual emission values. Customers, banks and tender specifications also demand verification in practice. The purely voluntary era is largely over.

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Resources

Allocation in LCA: The ISO 14044 Hierarchy and the Question Verifiers Ask Most

Functional Unit or Declared Unit? Before You Compare Two EPDs

EPD & CBAM Quarterly Outlook — Issue 1: 2026 Q3

Frequently Asked Questions

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