Rules for EPD of Multiple Products for IES

Rules for declaration of the EPD for multiple products in the International EPD system

Several sets of results, reflecting different products, are not allowed to be declared in the same EPD. However, similar products from a single or several manufacturing sites covered by the same PCR and manufactured by the same company with the same major steps in the core processes may be grouped and thereby included in the same EPD. For such an EPD, there are three options:

▪ For each indicator, declare the average results of the included products. This average shall be weighted according to the production volumes of the included products, if relevant. In this option, the average content shall be declared in the content declaration.

▪ Declare the results of one of the included products – a representative product. The choice of the representative product shall be justified in the EPD, using, where applicable, statistical parameters. For example, the choice may be based on production volumes. In this option, the content of the representative product shall be declared in the content declaration. 

▪ Declare the worst-case result of the included products, for the included modules from A to C, per declared environmental performance indicator (i.e., the results of a “worst-case product”, which may be the results of one or several of the included products). In this option, the content declaration shall include the lowest amounts of recycled and biogenic content of the included products and their packaging, respectively, and the information on environmental and hazardous properties of substances contained in the products shall reflect the highest share and most hazardous such substances contained in the any of the included products. For other parts of the content declaration, the average content shall be declared.

For all options, the range of the content of the included products should be included in the content declaration, in addition to the average/representative/worst-case content as specified above.

For EPDs claiming compliance with ISO 21930, the above options are only possible if none of the declared environmental impact indicator results, aggregated over all included modules (from A to C), differ by more than 10% between any of the included products. If the EPD does not claim compliance with ISO 21930, variations above 10% are allowed, if justified in the LCA report and the EPD declares the variation of each impact indicator results for which the variation is above 10%. The option chosen shall be clearly described at the cover page of the EPD, as “EPD of multiple products, based on the average results of the product group”, “EPD of multiple products, based on a representative product”, or “EPD of multiple products, based on worst-case results”.
In an EPD of multiple products based on average results or a representative product, the declared GWP GHG result for modules A1- A3 (A1-A5 for services) should not differ by more than 10% compared to the GWP-GHG results any of the included products. When there are larger variations, the grouping of products/sites shall be justified in the LCA report.
In an EPD of multiple products, the difference (in %) between the declared GWP-GHG result, and the product with GWP-GHG results furthest away from the declared results, for modules A1-A3 (A1-A5 for services), shall be reported in the EPD (see Table 3 in Section 5.4.3 for an example of how this can be declared). If this difference is below 10%, “<10%” can be reported. Optionally, this variation can instead be declared as the difference between the declared result and lowest and highest result, respectively (e.g., as “+8/-12%”).
In an EPD of multiple products, the GWP-GHG results of the “best-case product” and/or “worst-case product”, defined as the product with lowest/highest GWP-GHG results, may be reported in a subsection of the environmental performance section (see Section 5.4.5 of the PCR 1.3.2) and the content of this product (or these products) may be additionally reported in the content declaration (Section 5.4.4 of the PCR 1.3.2).

Identical products

Note that above paragraphs concern grouping of similar products, but not grouping of identical products (e.g., produced at different manufacturing sites or at different production lines at one site). Identical products here refer to products which are not marketed as different products and/or are in no other way distinguishable by a downstream customer (e.g., by colour, size, content or configuration). For identical products, variations due to, for example, manufacturing at several sites shall be treated as any other variation in production, by averaging over (normally) 1 year of production (and in such cases, variations above 10% are allowed also if compliance with ISO 21930 is claimed). However, the variation in GWP-GHG results for modules A1-A3 between sites shall still be reported in the EPD, if the variation is above 10%. The reported variation may be the difference between the declared results and the results of each of the included sites, or the difference between the declared results and the results of the sites with the highest and lowest results, respectively.

Although a variation above 10% is allowed in EPDs of identical products manufactured at several sites, it is recommended to separate the EPDs per site so that a variation below 10% is met, as certain national regulations considers an EPD to be “product specific” only when the variation between sites is below 10%. If an EPD covers several manufacturing sites in A3, the manufacturing sites shall be listed in the EPD.

Sector EPD

An industry association, or any other group of companies, may develop an EPD in the form of a sector EPD. A sector EPD declares the average product of multiple companies in a clearly defined sector in a clearly defined geographical area. For products covered in a sector EPD, the same declared/functional unit shall be applied. Sector EPDs shall describe the products and companies that are covered by the EPD. If the GWP-GHG results of a sector EPD differ by more than 10% for A1-A3 (A1-A5 for services) between represented products and sites, these variations shall be reported in the EPD and the reason for the variations shall be qualitatively described (see Table 3 for an example of reporting the variation). If the variation is below 10%, the actual variation or “<10%” shall be declared. Any communication of the results from a sector EPD should contain the information that the results are based on averages obtained from the sector as defined in the EPD. The communication shall not claim that the sector EPD results are representative for a certain manufacturer or its product. Section 5.4.8 of PCR 1.3.2 details more information that shall be declared in sector EPDs.