12. EPD Verification: What to Expect

Independent verification distinguishes EPDs from self-declared environmental claims. ISO 14025 mandates that someone independent of the EPD developer must review the underlying LCA and verify that the declaration follows requirements. This oversight creates credibility but it also creates a process that many manufacturers find opaque and sometimes frustrating.

Understanding what verifiers actually check, how the verification process works, and how to prepare makes verification productive rather than painful. Good verification improves EPD quality. Poor verification wastes time and money on back-and-forth over trivial issues while missing substantive problems.

This guide explains verification from the manufacturer’s perspective: what happens, what verifiers look for, how to prepare, and what to do when problems arise.

What Verification Actually Means#

Verification means an independent party reviews your EPD and underlying LCA to confirm:

Conformance with the PCR: Did you follow the Product Category Rules exactly? System boundaries correct? Required modules included? Impact categories calculated using specified methods?

Conformance with ISO 14040/44: Does the LCA meet general Life Cycle Assessment methodology requirements? Goal and scope appropriate? Inventory complete? Impact assessment methods properly applied? Interpretation reasonable?

Data quality adequacy: Do data sources meet quality requirements? Is primary data used where required? Are database selections appropriate? Is geographic and temporal relevance adequate?

Accuracy of the EPD document: Does the declaration accurately present the LCA results? Are tables correct? Is methodology clearly described? Are limitations stated?

Completeness of documentation: Can someone else understand what you did and potentially reproduce it? Is everything traceable and justified?

Verifiers don’t assess whether your product is environmentally good or bad. They assess whether your EPD is methodologically sound and follows the rules. A product with high environmental impacts can have a verified EPD. Verification means “done correctly” not “environmentally excellent.”

Types of Verification#

ISO 14025 distinguishes verification types with different stringency:

Independent internal verification: Someone within your organisation but independent of EPD development reviews the work. They weren’t involved in data collection or LCA modelling. This meets minimum ISO 14025 requirements for business-to-business EPDs if the programme operator allows it.

Independent external verification: Someone from outside your organisation but not necessarily accredited reviews the EPD. They have no connection to your company and bring objectivity.

Third-party verification: An accredited verification body recognised as independent of both the manufacturer and any interested parties conducts the review. This is the highest level and is mandatory for business-to-consumer EPDs.

Most major programme operators require third-party verification even for business-to-business EPDs. The credibility benefit outweighs the additional cost. When you see an EPD from EPD International, IBU, or similar operators, it underwent third-party verification by an approved verifier.

Who Can Be a Verifier#

Programme operators maintain lists of approved verifiers. These are individuals or organisations meeting competence requirements including:

LCA expertise: Deep understanding of ISO 14040/44 methodology, impact assessment, and data quality evaluation.

Product category knowledge: Familiarity with the product category’s manufacturing, use, and end-of-life characteristics. A verifier who knows construction products but not electronics shouldn’t verify electronics EPDs.

Standards knowledge: Understanding of ISO 14025, relevant construction standards like EN 15804, and programme operator requirements.

Independence: No conflicts of interest with the manufacturer or financial stake in EPD outcomes.

Most verifiers are environmental consultants, academics, or technical experts working for certification bodies. They’re typically LCA practitioners with years of experience and specific training in EPD verification.

Some manufacturers engage verifiers early for preliminary reviews. Others wait until EPD completion. Early engagement can catch problems but adds cost and time. Late engagement risks discovering major issues requiring substantial rework.

What Verifiers Actually Check#

Verification involves systematic review of multiple elements.

PCR Compliance Matrix#

Verifiers check every PCR requirement against your EPD:

• Correct functional or declared unit? ✓ or ✗
• All required life cycle modules included? ✓ or ✗
• System boundaries match PCR specifications? ✓ or ✗
• Required impact categories calculated? ✓ or ✗
• Correct impact assessment methods used? ✓ or ✗
• Allocation rules followed? ✓ or ✗
• Data quality requirements met? ✓ or ✗

PCR compliance is binary. Either you followed the rules or you didn’t. This makes verification straightforward in principle but reveals problems clearly.

LCA Model Review#

Verifiers examine the actual LCA calculations, not just the EPD document:

Process structure: Are processes defined correctly? Do material and energy flows connect properly? Are background processes from databases linked appropriately?

Unit conversions: Are all units correct and consistent? Verifiers catch errors like confusing kg with tonnes, or MJ with kWh.

Database selections: For each input using database values, is the selected dataset appropriate? European electricity for European manufacturing? Appropriate transport distances and modes?

Allocation approaches: For co-products or recycling, are allocation rules applied correctly according to PCR specifications?

Scenario modelling: For life cycle stages beyond direct control, are scenarios reasonable and documented?

Calculation accuracy: Do manual calculations check out? Do software-generated results make sense? Are there obvious errors or anomalies?

This review is highly technical. Verifiers run test calculations, check formulas, and verify that LCA software is used correctly.

Data Quality Assessment#

Verifiers evaluate whether data meets quality criteria:

Primary data coverage: Is the percentage of primary data adequate for processes you control? PCRs typically require majority primary data for Module A3.

Data sources: Are sources documented and credible? Production records, utility bills, supplier data, and peer-reviewed databases are credible. Unsourced estimates or outdated information raises questions.

Representativeness: Does data reflect actual typical production? One month of unusual production isn’t representative. Annual averages work better.

Completeness: Have you included all significant inputs and outputs? Cut-off criteria (typically 1% mass and impact) should be documented.

Geographic relevance: Are databases and energy mixes appropriate for manufacturing locations? Chinese manufacturing shouldn’t use European electricity data.

Temporal relevance: Is data current? Databases more than 10 years old or production data from processes no longer used need updating.

Verifiers won’t accept “we don’t have that data” for critical information. They’ll require you to obtain it or make conservative documented assumptions.

EPD Document Accuracy#

Verifiers compare the EPD document to underlying calculations:

Results tables: Do numbers in the EPD match LCA output? Transcription errors are surprisingly common.

Methodology description: Is the approach clearly described? Can readers understand what was done?

Assumptions and scenarios: Are these stated clearly? Are limitations acknowledged?

Technical information: Is product description accurate? Are claimed properties supported?

References: Are all required references included? PCR, standards, databases, characterisation methods?

Verification statement requirements: Does the document include space for the verification statement? Is required programme operator information present?

This review catches presentation errors even when underlying calculations are correct.

Supporting Documentation#

Verifiers need more than the EPD document. They require:

Complete LCA model or detailed calculation spreadsheets showing all steps.

Data compilation with sources documented for every significant input.

Database documentation showing which datasets were used and why.

PCR compliance justification explaining how each requirement was addressed.

Allocation justification if complex allocation situations exist.

Scenario documentation explaining assumptions for transport, use, and end-of-life stages.

Incomplete documentation extends verification timelines. Verifiers won’t assume information is correct if they can’t see evidence.

The Verification Process Timeline#

Verification typically follows this sequence:

Initial submission: You provide the EPD draft, LCA model, and supporting documentation to the verifier.

Preliminary review (1-2 weeks): The verifier conducts initial assessment, identifies obvious issues, and prepares a question list.

First round questions: Verifiers send questions, requests for clarification, and identification of problems. This might be 10-50 questions depending on EPD complexity and documentation quality.

Your responses (1-2 weeks): You address questions, provide missing information, correct errors, and update documentation. Response speed affects total timeline.

Iterative review: Verifiers assess your responses. Major problems might require model revisions and recalculation. Minor issues need documentation updates. This might involve multiple rounds.

Final review: Once all issues are resolved, verifiers conduct final checks and prepare the verification statement.

Verification statement issuance: The verifier provides a signed statement confirming EPD conformance with standards and PCR.

Total verification time ranges from two weeks (straightforward EPDs with excellent documentation) to three months (complex products with data issues and multiple revision rounds). Typical verification takes four to eight weeks.

Common Verification Problems#

Certain issues appear repeatedly in verification:

Incomplete Data Documentation#

Problem: “You claim 500 kWh electricity per tonne. What’s the source?”

Fix: Provide utility bills, production records, and calculations showing how you derived the per-unit value.

Prevention: Document sources as you collect data, not after verification begins.

Wrong Database Selections#

Problem: “You selected European electricity but manufacturing is in China. Why?”

Fix: Correct the database selection to appropriate regional data and recalculate.

Prevention: Check geographic relevance of every database selection during LCA modelling.

Allocation Errors#

Problem: “You allocated co-product impacts by mass but the PCR requires economic allocation.”

Fix: Redo allocation calculations using correct method. This might significantly change results.

Prevention: Read PCR allocation requirements carefully before modelling.

Missing Modules#

Problem: “The PCR requires Module D but it’s not included.”

Fix: Calculate Module D following PCR specifications. This requires additional modelling.

Prevention: Check which modules are mandatory versus optional in the PCR.

Unit Confusion#

Problem: “Module A1-A3 climate change shows 0.45 kg CO₂e per kg but detailed data suggests this should be 450 kg per tonne. Did you drop three zeros?”

Fix: Correct the unit error and update results tables.

Prevention: Be obsessively careful with units. Label everything clearly.

Optimistic Scenarios#

Problem: “Module D assumes 95% recycling but regional data shows 60%. Justify this assumption.”

Fix: Either revise the scenario to match realistic conditions or provide evidence supporting the higher recycling rate.

Prevention: Use conservative realistic scenarios, not best-case optimism.

Inconsistent Documentation#

Problem: “The EPD says primary data covers 80% but the data compilation shows 55%. Which is correct?”

Fix: Recalculate primary data percentage correctly and ensure EPD and documentation agree.

Prevention: Cross-check everything before submission. Numbers should be consistent across all documents.

How to Prepare for Smooth Verification#

Good preparation dramatically reduces verification pain:

Before Engaging the Verifier#

Internal quality checks: Have someone uninvolved in EPD creation review everything. Catch obvious errors internally rather than during verification.

Documentation completeness: Ensure every data point has a documented source. Fill all sections of the PCR compliance matrix. Provide clear methodology explanation.

PCR compliance verification: Systematically check you’ve addressed every PCR requirement. Create a checklist and confirm each item.

Calculation spot-checks: Manually verify key calculations. Do results make intuitive sense? Is climate change impact reasonable for your product type?

Results comparison: Compare your results to similar EPDs if available. Large discrepancies warrant investigation before verification.

During Verification#

Respond promptly: Verifier questions sitting unanswered for weeks extend timelines. Allocate time for verification interactions.

Be thorough: When responding to questions, provide complete answers with supporting documentation. Partial responses lead to follow-up questions.

Explain logic: When verifiers question assumptions, explain your reasoning clearly. Good justifications based on product knowledge often satisfy concerns.

Accept corrections: If verifiers identify errors, fix them rather than defending mistakes. Good verifiers improve EPD quality.

Track changes: Document what you change in response to verification. This creates an audit trail and prevents confusion.

Communication with Verifiers#

Be professional but human: Verifiers are technical partners, not adversaries. Clear communication about constraints, data limitations, or problems works better than defensive responses.

Ask for clarification: If verifier comments are unclear, ask for explanation. Misunderstanding questions leads to inadequate responses.

Provide context: Manufacturing realities sometimes prevent perfect data. Explaining constraints helps verifiers understand why certain approaches were necessary.

Escalate appropriately: If verification seems unreasonable, contact the programme operator. They can clarify requirements or mediate disputes.

What Verification Costs#

Verification fees vary based on:

Product complexity: Simple products with straightforward manufacturing verify faster than complex multi-component products.

Documentation quality: Well-documented EPDs verify quickly. Poor documentation requires more verifier time investigating.

EPD experience: First EPDs typically require more verification effort than updates or subsequent products.

Verifier rates: Different verifiers charge different rates, typically £100-200 per hour or fixed fees.

Geographic factors: Regional variation in costs affects overall fees.

Typical verification costs range £2,000-5,000 for construction products, potentially more for complex products or if multiple verification rounds are needed. Simple products with excellent documentation might cost less. Complex products with data issues might cost more.

Budget verification as a fixed cost of EPD creation. Trying to minimise verification costs by cutting corners on documentation usually backfires when problems extend timelines and require additional revisions.

When Verification Fails#

Sometimes EPDs don’t pass verification on first attempt. Major issues might prevent verification approval until addressed:

Fundamental methodology problems: System boundaries violating PCR, wrong impact assessment methods, or critical allocation errors require fixing before verification continues.

Inadequate data quality: If primary data coverage falls far short of requirements or key data sources are missing, you might need to collect additional information.

Calculation errors: Significant errors affecting results substantially require correction and recalculation.

Verification failure isn’t the end. It’s feedback that problems need fixing. Address the issues identified, make necessary corrections, and resubmit. Verifiers want EPDs to succeed. They provide detailed feedback enabling corrections.

Life After Verification#

Once verification completes, the verifier provides a statement confirming:

• The EPD was reviewed
• It conforms to the PCR and applicable standards
• Data quality is adequate
• The declaration accurately represents the product’s environmental performance

This statement gets included in the published EPD. It’s the mark of credibility that distinguishes verified EPDs from unverified claims.

The verified EPD then moves to registration and publication with the programme operator.

Using Verification Feedback Productively#

View verification as quality improvement, not just compliance:

Learn for future EPDs: First verification teaches you what verifiers prioritise. Apply those lessons to subsequent EPDs for smoother processes.

Improve data systems: Verification often reveals data gaps. Use this feedback to strengthen data collection for future updates.

Build relationships: Verifiers who work well with you become valuable resources for future projects. They understand your products and processes.

Document lessons learned: Create internal guidance capturing what verification taught you. This knowledge transfer helps others in your organisation.

Choosing Your Verifier#

Programme operators maintain approved verifier lists. Within those lists, consider:

Relevant experience: Verifiers familiar with your product category understand manufacturing realities and environmental aspects better than those learning your sector during verification.

Communication style: Some verifiers are highly collaborative, discussing problems early. Others work more independently. Choose a style matching your preferences.

Availability: Verifiers with long queues delay timelines. Check availability before committing.

Cost: Compare fees among qualified verifiers. Cheapest isn’t always best if slower or less thorough.

References: Ask other manufacturers in your sector about their verifier experiences. Recommendations matter.

Some manufacturers engage verifiers for preliminary reviews before formal verification. This catches problems early but adds cost. For first EPDs or complex products, early verifier engagement can prevent larger problems later.

Final Thoughts on Verification#

Verification requirements make EPD creation more rigorous than carbon footprinting or unverified LCA. This rigour creates EPD credibility. When someone sees a verified EPD, they know independent experts checked the work.

Approach verification as partnership rather than obstacle. Good verifiers improve your EPD quality. They catch errors, question assumptions, and ensure methodology soundness. The result is a declaration you can confidently present to customers, regulators, and markets.

Prepare thoroughly, document completely, respond promptly, and accept corrections graciously. Verification becomes a productive process rather than a frustrating barrier. The verification statement on your published EPD represents successful navigation of rigorous technical review. That credibility is worth the effort required to achieve it.