Product Carbon Footprint Calculation to ISO 14067 for Exporters

What is a product carbon footprint calculation, and what does support add?

It is the quantification, in CO2 equivalent per unit of product, of the greenhouse gas emissions and removals linked to a product over its whole life cycle or part of it. Support mainly stops you from calculating the wrong number: it starts from what your buyer expects, then builds a model your team can update alone.

The reference standard is ISO 14067:2018 — Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification (formerly ISO/TS 14067:2013, withdrawn). According to its abstract on iso.org, read on 11 November 2026, it covers the quantification and reporting of a full or partial footprint, consistently with the life cycle assessment standards ISO 14040 and ISO 14044; it addresses climate change only, and leaves offsetting and communication out of scope. It is under revision: draft ISO/WD 14067.2 at stage 20.60 on iso.org on 11 November 2026. The 2018 edition is the one that applies.

This page describes the service. The standard itself (functional unit, allocation, biogenic carbon, difference from a corporate inventory) is explained in our product carbon footprint ISO 14067 guide.

Which deliverable for which request: PCF report, EPD, PEF study or CBAM embedded emissions?

Each request calls for a different deliverable, even when the buyer just says “carbon”. Identifying the right one in the first exchange saves redoing the study.

Three practical points:

• An ISO 14067 footprint is neither an EPD nor a PEF study. EPDs and PEF studies are multi-impact; they include a climate change indicator, but other impact categories too.
• An EPD is a registered public document with its own verification and update rules; a PCF report usually stays a document sent to the customer.
• One plant may need two separate calculations from the same data: for example an EPD under EN 15804+A2 for a construction buyer and CBAM embedded emissions for an importer, if it makes cement, steel or aluminium.

Which exporters receive these requests, and in what form?

Mainly suppliers of materials, components and intermediate products sold to European manufacturers, whose footprint feeds their customer’s purchased-goods emissions. The deliverable and the unit vary by sector.

These requests often sit inside a broader ESG questionnaire: see CSRD, VSME and ESG questionnaires. When the buyer sets its own calculation method, apply it and say so in the report.

How do you choose the calculation rules: PCR, PEFCR, EN 15804+A2 or ISO 14067 alone?

By first checking whether a rule already exists for your product and the intended use: it takes precedence over your own choices. ISO 14067:2018 alone, with written choices, applies only when no sector rule is imposed.

Our search order:

1. The customer’s own method. Some buyers supply a calculation guide or a reporting format that fixes the unit, the boundary and sometimes the databases.
2. A PEFCR, if the customer works with the PEF method. Commission Recommendation (EU) 2021/2279 of 15 December 2021 says it should be used where one exists for the product category.
3. EN 15804:2012+A2:2019 (which replaced EN 15804:2012+A1:2013) for an EPD of a construction product in Europe: it sets the core product category rules for the sector.
4. An EPD programme PCR for other products, when the customer wants an EPD or a comparison with published declarations.
5. ISO 14067:2018 alone, with written choices on unit, boundary, cut-offs and allocation, agreed with the customer before calculation.

The same product may fall under two rule sets depending on the customer: one parameterised model beats one spreadsheet per request.

What data do you need for a cradle-to-gate calculation?

Your plant’s data for everything you control, your key suppliers’ data for the materials that matter, and documented secondary data for the rest. Result quality depends first on the share of primary data on the big items.

For transport, ISO 14083:2023 (formerly IWA 16:2015) — Greenhouse gases — Quantification and reporting of greenhouse gas emissions arising from transport chain operations provides a common method: ask your carriers for compatible data.

Each secondary dataset is cited with its database, version, year and licence; this page deliberately gives no emission factor values. Purchased electricity, on-site solar, biogenic carbon and allocation between products on one site get written rules and a sensitivity analysis, because reviewers question them most.

If your site already has a corporate carbon footprint to ISO 14064, its energy and refrigerant data are reused: data collection is organised once. Our ISO 14064-1 guide explains how the two exercises connect.

How do you get from a footprint to a registered EPD?

By adding the EPD programme’s requirements to the study: its PCR, impact categories, declaration format, verification and registration. The carbon footprint is just one indicator in it.

The reference standard is ISO 14025:2026 — Environmental statements and programmes for products — Environmental product declarations (EPDs) (formerly ISO 14025:2006, withdrawn). This second edition, published in June 2026, sets the principles and requirements for EPD programmes and their declarations, and requires life cycle assessment under ISO 14040 and ISO 14044. Construction products sold in Europe also follow EN 15804+A2.

For an EPD we prepare the programme and PCR choice with you, the full multi-impact LCA under the PCR, the project report for the verifier, the draft declaration, and the evidence file. Verification and registration belong to the programme and an independent verifier; ACG neither registers nor verifies EPDs. If your current EPD cites ISO 14025:2006, ask the programme how it treats earlier declarations: iso.org showed no transition period on 11 November 2026.

What does the digital product passport (ESPR) mean for your carbon data?

It lets the EU require, product group by product group, information on the carbon or environmental footprint of products placed on its market, imports included. Nothing is automatic: each obligation comes from a delegated act specific to a product group.

Regulation (EU) 2024/1781 of 13 June 2024 establishing a framework for setting ecodesign requirements for sustainable products (ESPR), published in the Official Journal on 28 June 2024, repeals Directive 2009/125/EC. Read on EUR-Lex on 11 November 2026:

• Article 5: ecodesign requirements set by delegated acts may address environmental impacts, including carbon footprint and environmental footprint;
• Annex I: the product’s carbon footprint and environmental footprint are among the product parameters those requirements may be based on;
• Article 7: information requirements may require products to come with information on their performance against those parameters, including a carbon footprint or an environmental footprint;
• Article 9: where a delegated act provides for it, a product may only be placed on the market if a digital product passport is available;
• Recitals: such life-cycle indicators should be calculated taking into account methods established internationally and already used in EU law; the text refers to the PEF method.

For an exporter, this means that once a delegated act covers your product group and requires a footprint, its method will apply and your importer will ask for compatible data. As of 11 November 2026, EUR-Lex lists only one delegated act based on the ESPR, Delegated Regulation (EU) 2026/296 on derogations from the ban on destroying unsold clothing and footwear: no act has yet set requirements for a product group or required carbon or environmental footprint information, and the working plan of 16 April 2025 gives only indicative years (2026 for iron and steel, 2027 for textiles, aluminium and tyres); details in our article on the ESPR digital product passport. Until then, an up-to-date life-cycle model is the best preparation.

Which climate claims can you make with your footprint?

Specific claims, limited to what is measured and can be demonstrated. A sound footprint supports a quantified reduction claim on a defined boundary; it does not support a neutrality claim based on offsetting.

Directive (EU) 2024/825 on empowering consumers for the green transition applies from 27 September 2026 (Article 4, read on EUR-Lex on 11 November 2026). It adds to the commercial practices banned in all circumstances (Annex I to Directive 2005/29/EC) claiming, based on greenhouse gas offsetting, that a product has a neutral, reduced or positive impact on the environment in terms of emissions (point 4c), and making a claim about the entire product when it concerns only one aspect of it (point 4b).

On the standards side, ISO 14021:2026 — Environmental statements and programmes for products — Self-declared environmental claims (formerly ISO 14021:2016) governs self-declared claims, and carbon neutrality falls under ISO 14068:2026 (formerly ISO 14068-1:2023; according to iso.org, only the number and title changed). More in Directive 2024/825 and environmental claims, our ISO 14068 guide and carbon neutrality ISO 14068.

Our position: reduce first, claim only what is proven, and have any claim aimed at EU consumers reviewed before printing or publishing.

How do you prepare for critical review or verification?

By keeping, from the first calculation, a file that lets a third party trace each result to its data and each choice to its justification. Review or verification is always done by an independent party, never by whoever did the calculation.

According to iso.org, ISO 14064-3:2019 applies to the verification of product GHG statements, as well as organisation and project statements. ISO 14040:2006 and ISO 14044:2006 cover the critical review of LCA studies. Recommendation (EU) 2021/2279 requires PEF studies disclosed to third parties to be verified. Agree with your customer, before verification starts, on the verification standard and the level of assurance.

Checklist: is your product carbon footprint file ready?

Go through these points before sending a figure to a buyer or starting verification.

• The customer’s request is in writing: deliverable, standard, products, format, deadline, verification.
  
• You looked for a customer method, a PEFCR, a programme PCR or EN 15804+A2 before making your own choices.
  
• The declared or functional unit and the boundary (cradle to gate, cradle to grave) are written down.
  
• The system boundary and cut-off rules are listed; every exclusion is justified.
  
• The data year covers twelve consecutive, documented months.
  
• Each SKU’s bill of materials is up to date.
  
• Energy is metered per workshop or line, or a written allocation key replaces it.
  
• The allocation rule between products on one site is written and tested for sensitivity.
  
• Suppliers of the heaviest materials have been asked for primary data.
  
• Every secondary dataset has its database, version, year and licence.
  
• Transport data are compatible with ISO 14083:2023.
  
• You checked whether your products fall under CBAM, and whether an ESPR delegated act covers their product group.
  
• Any planned claim has been reviewed against Directive (EU) 2024/825 and ISO 14021:2026.
  
• The file lets an independent party redo the calculation.
  
• Update triggers are written down.
  

When should a product carbon footprint be updated?

Whenever a change significantly alters the result, and at the frequency set by the customer or the EPD programme. Write the triggers in advance, with a threshold, as for a corporate inventory.

Usual triggers: a new process or line, a new supplier for a major material, a switch to renewable or self-generated electricity, a change in bill of materials or weight, a new PCR or PEFCR version, and a new edition of ISO 14067 once published. A reduction from a real lever (less energy, less scrap, recycled material) only shows at the update, which is also how you prove it to your customer. The levers themselves are covered in decarbonisation strategy.

What ACG does for your product carbon footprint

ACG scopes the request, builds the model, collects and calculates, writes the report or EPD file and trains your team; an independent party verifies. The firm counts 502 projects, 10 in-house consultants and more than 100 qualified external experts, and has trained more than 120,000 people.

For your team, see our training catalogue. For all your ESG requests, see ESG and CSR; if your environmental management system is certified to ISO 14001, its energy and waste indicators are a starting point for data collection. To start, describe your customer’s request.