EPD ISO 14025: Environmental Product Declaration Guide for Exporters

What is an EPD under ISO 14025?

An EPD is a public document that reports the quantified life cycle assessment (LCA) results of a product, against indicators fixed in advance, using calculation rules shared across its product category, and with independent verification. Its purpose is to let buyers compare products that perform the same function on a common basis.

The reference standard is ISO 14025:2026 — Environmental statements and programmes for products — Environmental product declarations (EPDs) (formerly ISO 14025:2006, now withdrawn). According to its abstract on iso.org, read on 11 November 2026, this second edition, published in June 2026, sets out principles and requirements for EPD programmes and the declarations they publish, and requires ISO 14040 and ISO 14044 to be used when developing EPDs. It covers the potential environmental impacts and environmental aspects of products; related social or economic aspects may be added as additional information, but the standard does not deal with social or economic LCA indicators. Sector-specific provisions sit in other documents, which are meant to build on its principles.

The introduction to the standard, freely viewable on iso.org, gives four defining features. An EPD:

• is provided by one or more organisations (a manufacturer, a group of manufacturers, a trade association);
• is based on independently verified LCA data, in line with ISO 14040 and ISO 14044;
• uses predetermined impact and inventory indicators, set by the product category rules (PCRs);
• is administered by a programme operator that acts objectively and avoids conflicts of interest.

An EPD does not claim that one product is preferable to another: the standard states that it is not in itself a comparative assertion. It provides the data that lets a buyer, specifier or project owner make the comparison.

Where the EPD sits among environmental statements

ISO 14025 belongs to a family of standards from subcommittee ISO/TC 207/SC 3. Each covers one form of “environmental statement”, the term that replaces “environmental label” and “environmental declaration” in recent editions.

ISO 14020:2022 has an amendment under development (ISO 14020:2022/DAmd 1, stage 40.60 on iso.org as of 11 November 2026); no new edition has been announced. Ecolabels and self-declared claims are not covered in detail here: this guide focuses on the EPD.

What changed in ISO 14025:2026 compared with the 2006 edition?

The 2026 edition keeps the core idea of a verified, LCA-based declaration, but changes the vocabulary, moves general requirements into ISO 14020 and strengthens comparability, PCR review and verification. Its foreword says it was prepared in collaboration with CEN, the European Committee for Standardization.

According to the foreword freely available on iso.org (read on 11 November 2026), the main changes are:

1. New title. “Environmental labels and declarations — Type III environmental declarations — Principles and procedures” becomes “Environmental statements and programmes for products — Environmental product declarations (EPDs)”.
2. New vocabulary. “Environmental label”, “environmental declaration” and “Type III environmental declaration” are deprecated in favour of “environmental statement” and “EPD”.
3. General requirements moved to the revised ISO 14020, now a normative reference.
4. ISO/TS 14027 (development of PCRs) and ISO/TS 14029 (mutual recognition of EPDs and programmes) become normative references.
5. Additional information. The standard explains how to include additional environmental or other sustainability-related information that does not come from the LCA.
6. EPD types. A new clause covers the different types of EPD, including “prospective” types.
7. Comparability. A new Annex C deals with harmonising PCRs and programmes.
8. PCR review and verification. Requirements on programmes are made more specific.
9. EPD tools. New requirements cover software tools that automate EPD generation.

One more visible shift: according to its iso.org abstract, the 2006 edition was intended mainly for business-to-business communication, without excluding consumers; the 2026 edition has a full clause (Clause 10) with additional requirements for EPDs aimed at consumers.

What about your existing EPDs? A declaration published under ISO 14025:2006 does not become wrong on the day the 2026 edition appears; the programme decides how and when it moves its general instructions to the new edition. iso.org shows no transition period as of 11 November 2026. Ask your programme operator in writing, and stop quoting the 2006 edition as current in data sheets and tender responses.

How do EPD programmes, PCRs and verification work?

An EPD programme sets its general rules, has PCRs developed and reviewed for each product category, organises independent verification and publishes the declarations. The manufacturer chooses a programme, applies the PCR for its category, has the LCA carried out and then verified.

Who does what

PCRs make comparison possible

Product category rules (PCRs) fix, for a product family, the declared or functional unit, the life cycle stages covered, cut-off and allocation rules, scenarios, the indicators to declare and the format. Two EPDs are only comparable if they follow equivalent rules, which is why ISO 14025:2026 encourages programmes to harmonise their PCRs and agree mutual recognition arrangements, based on ISO/TS 14027 and ISO/TS 14029.

Before any LCA work, look for your product’s PCR in the programmes your customer accepts. If none exists, a PCR has to be developed and reviewed, which lengthens the project considerably.

Verification

According to the introduction to ISO 14025:2026, programmes must ensure that both the LCA data and the EPD are independently verified. That verification can be internal or external to the declaring company; it need not be third-party, except for EPDs aimed at consumers, where the standard requires third-party verification (Clause 10). Many programmes and buyers require an external verifier in every case: read the programme’s general instructions.

Choosing a programme

The right programme is first of all the one your customer accepts. A Moroccan or African exporter often sells into several European countries; ask these questions before signing up:

• Do your customers and target tenders accept this programme?
• Is there a published, valid PCR for your product category?
• Does the programme have mutual recognition arrangements with other programmes?
• Which background databases, and which versions, does the PCR require or accept?
• Who appoints the verifier, and on what competence criteria?
• What validity period, update rules, publication and maintenance fees apply?
• Has the programme already aligned its rules with ISO 14025:2026?

Why EN 15804+A2 for construction products, and what does Regulation (EU) 2024/3110 change?

In Europe, EN 15804:2012+A2:2019 is the core PCR for all EPDs of construction products and services, and the new EU Construction Products Regulation brings life cycle indicators into the manufacturer’s regulatory declaration. Exporters of cement, tiles, aluminium profiles or insulation are directly affected.

EN 15804+A2

EN 15804:2012+A2:2019 (with its 2021 corrigendum) replaced EN 15804:2012+A1:2013, which is no longer current. Its summary, published by the Dutch standards body NEN and read on 11 November 2026, says it provides core PCRs for environmental declarations (still called “Type III” in that summary) for any construction product and service, and that it:

• defines the indicators to declare and how to report them;
• describes the life cycle stages considered and the processes to include;
• sets rules for developing scenarios;
• sets rules for calculating the inventory and impact assessment, including data quality;
• defines the conditions under which construction products can be compared on the basis of their EPDs.

ISO 14025:2026 itself illustrates, in Annex B, the four common life cycle stages of a construction product and their information modules. A programme’s complementary PCRs then refine EN 15804+A2 for a given category (cement, ceramics, aluminium…).

Regulation (EU) 2024/3110 on construction products

Regulation (EU) 2024/3110 of 27 November 2024 laying down harmonised rules for the marketing of construction products, published in the Official Journal on 18 December 2024, repeals Regulation (EU) No 305/2011. Read on EUR-Lex on 11 November 2026:

Two points prevent misreadings:

• The regulation’s declaration is not a programme EPD. It is a regulatory declaration calculated with the Commission’s software; recital 7 says the software should apply characterisation factors under EN 15804 or future standards. The inventory data gathered for an EN 15804+A2 EPD remains the best preparation.
• Nothing is automatic for your product. Harmonised standards listed under Regulation No 305/2011 and in force on 8 January 2026 remain valid until withdrawn (Article 95(3)). As of 11 November 2026, the EUR-Lex record of the regulation lists three delegated regulations supplementing it (reaction-to-fire classes, resistance-to-fire classes, assessment and verification systems) and two Commission proposals that would amend it, COM(2026) 100 and COM(2026) 590, not adopted. On the same date, EUR-Lex lists only one implementing act based on the regulation, Commission Implementing Regulation (EU) 2026/387 of 23 February 2026, which sets the format of the European Technical Assessment (Article 37(4)): no implementing act has yet been adopted under Article 5(8) or Article 6(1). No family of construction products, whether exported from Morocco or not, is therefore yet required to declare the climate indicators; a family will be, at the earliest, one year after the adoption of the act that covers it (Article 95(9)).

The regulation also provides for a digital product passport for construction products (Article 75), aligned as far as possible with the digital product passport of Regulation (EU) 2024/1781 (ESPR). ESPR information requirements, for their part, arise from delegated acts specific to each product group: see our product carbon footprint page.

EPD, ISO 14067 carbon footprint or PEF study: which should you give your customer?

Whatever the customer asks for, under the rule they name. An EPD is multi-indicator and public; an ISO 14067 carbon footprint covers climate only and usually stays a document sent to the customer; a PEF study follows the EU multi-indicator method. None of them replaces the embedded emissions required under the EU CBAM.

ISO 14067:2018 — Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification is under revision (draft ISO/WD 14067.2 at stage 20.60 on iso.org as of 11 November 2026); the 2018 edition remains current. A well-built multi-indicator LCA for an EPD also delivers the climate change indicator; the reverse is not true. If different customers ask for both, build one life cycle model, set up for each rule.

Commission Recommendation (EU) 2021/2279 of 15 December 2021 recommends the Product and Organisation Environmental Footprint methods (PEF and OEF); an ISO 14025 EPD is not a PEF study, even though both rest on LCA. The CBAM, in its definitive period since 1 January 2026, requires a separate calculation per installation: see CBAM for exporters.

For more detail, read our ISO 14067 product carbon footprint guide and our comparison of carbon footprint, LCA and product carbon footprint.

How do you prepare an EPD, step by step?

Start with the customer’s request and the PCR, not with the calculation. The rest follows the order of a verified LCA: scope, data collection, modelling, project report, verification, publication, updates.

1. Clarify the request. Which product, which market, which accepted programme, which standard (ISO 14025:2026 alone, or EN 15804+A2), which tender deadline.
2. Choose the programme and PCR. Check the PCR’s validity, required databases, declared unit and mandatory life cycle stages.
3. Set the scope. Declared or functional unit, single product or an average of several products or sites where the PCR allows it, data year, cut-off and allocation rules.
4. Collect site data. Bills of materials, energy per workshop, yields, scrap, packaging, transport, waste, process emissions; primary data from suppliers of the materials that weigh most.
5. Model and calculate. LCA under ISO 14040 and ISO 14044 and the PCR, with documented secondary data (database, version, year) and a sensitivity analysis.
6. Write the project report and draft EPD. The project report, written for the verifier, documents every choice; the EPD follows the programme’s format.
7. Get it verified. An internal mock review, then independent verification and closure of findings.
8. Publish and keep it current. Publication by the programme, tracking of the expiry date and of update triggers (process, supplier, electricity supply, new PCR version).

A ceramic tile maker in the Fez region answering a European tender, for instance, saves weeks if it already has energy meters on each kiln and an up-to-date bill of materials: firing and raw materials are the items the verifier will examine most closely. An aluminium profile maker will also have to keep its EPD separate from its CBAM data, which follow a different method.

Checklist: is your EPD project ready?

• The customer’s request is in writing: product, market, accepted programme, standard, deadline.
  
• A valid PCR exists for your category, or you have planned its development.
  
• You know whether EN 15804+A2 applies (construction product or service).
  
• The declared or functional unit, life cycle stages and data year are written down.
  
• Cut-off and allocation rules follow the PCR, or are justified in writing.
  
• Energy is metered per workshop or line, or a written allocation key replaces it.
  
• Suppliers of the main materials have been asked for primary data.
  
• Every secondary dataset has its database, version and year.
  
• The project report lets a verifier trace every result back to its data.
  
• The verifier is independent of whoever carried out the LCA.
  
• Your sales documents no longer cite ISO 14025:2006 as current.
  
• You have checked whether your products fall under the CBAM and under an implementing act of Regulation (EU) 2024/3110.
  
• Update triggers and the expiry date are tracked.
  

Can you use an EPD in marketing?

Yes, as a source of accurate, verified data, not as a “green” product label. Quote the results with their unit, scope and the declaration’s reference; do not turn them into a generic claim, a comparison the PCR does not support, or a climate-neutral claim.

Three sets of rules frame this use:

• The standard itself. ISO 14025:2026 states that an EPD is not a comparative assertion; a comparison only makes sense between EPDs built on equivalent rules. For EPDs aimed at consumers, Clause 10 adds information requirements and requires third-party verification.
• EU consumer law. Directive (EU) 2024/825, empowering consumers for the green transition, has applied since 27 September 2026. Towards EU consumers it bans, in all circumstances, generic environmental claims without recognised excellent environmental performance (point 4a of Annex I to Directive 2005/29/EC), claims about the whole product that are true only of one aspect (point 4b), sustainability labels not based on a certification scheme or set up by public authorities (point 2a), and neutrality claims based on offsetting (point 4c). The proposed Green Claims Directive has not been adopted as of 11 November 2026. More in our article on Directive 2024/825 and environmental claims.
• The rest of the family. A single statement about recycled content falls under ISO 14021:2026 — Self-declared environmental claims; a logo awarded against criteria falls under ISO 14024:2026 — Ecolabels. Carbon neutrality falls under ISO 14068:2026 (formerly ISO 14068-1:2023): see our ISO 14068 carbon neutrality page.

Our position: publish verified data, reduce the impacts the EPD reveals, and have any statement aimed at EU consumers reviewed before it is printed or posted online.