9. Choosing an EPD Programme Operator

Every EPD exists within a programme run by a programme operator. This isn’t optional infrastructure. Your choice of programme operator affects who recognises your EPD, what rules you follow, what costs you incur, and how your declaration fits into green building certification and regulatory compliance.

Making the wrong choice doesn’t invalidate your EPD technically, but it can mean your EPD isn’t recognised where you need it, costs more than necessary, or requires redoing under different programmes later. Understanding what programme operators do and how to evaluate them helps you choose wisely rather than discovering problems after investing time and money.

This article focuses on practical selection criteria. We won’t exhaustively list every programme globally (there are dozens) but we’ll cover the major systems and explain how to evaluate any programme you’re considering.

What Programme Operators Actually Do#

Programme operators establish and maintain the framework that makes EPDs credible and comparable. Under ISO 14025, operators must:

Establish general programme instructions defining scope, procedures, stakeholder involvement, and verification requirements. These instructions determine how the programme works.

Develop or approve Product Category Rules. Operators either create PCRs for product categories or approve PCRs developed by others. The PCR determines exactly how your EPD must be created.

Maintain public registries of PCRs and published EPDs. Anyone can search these registries to find declarations.

Approve and monitor verifiers. Operators qualify verification bodies and ensure they maintain competence.

Set and collect fees. Registration fees, annual fees, and other costs vary between programmes.

Ensure quality and compliance. Operators review EPDs before publication to confirm they meet programme requirements.

Different operators make different choices within ISO 14025’s framework. Some run strict centralised systems. Others allow more flexibility. Some focus on specific sectors. Others cover diverse product categories. These differences matter for your selection.

Major International Programme Operators#

Several programme operators have broad international recognition and diverse product coverage.

EPD International (The International EPD System) operates globally with headquarters in Sweden. It’s probably the most widely recognised programme internationally. The system covers diverse product categories from construction materials to food and electronics. EPD International maintains extensive PCR libraries and has mutual recognition agreements with multiple regional programmes.

The International EPD System is often the default choice for manufacturers targeting global markets or multiple regions. Recognition in green building schemes worldwide is strong. The programme operator charges reasonable fees and provides good English-language support.

Website: environdec.com

IBU (Institut Bauen und Umwelt) dominates German and Central European markets, particularly for construction products. IBU EPDs are widely recognised in German green building projects and increasingly throughout Europe. The programme has detailed PCRs for construction products and strong technical support.

IBU makes sense for manufacturers focused on German-speaking markets or where German architects and developers are key customers. The programme operates primarily in German, though English support exists.

Website: ibu-epd.com

UL Environment (part of UL Solutions) operates a North American focused programme. For manufacturers selling primarily in US and Canadian markets, UL’s programme provides strong recognition. The system integrates well with LEED and other North American green building schemes.

Website: ul.com/services/environmental-product-declarations-epds

Regional Programme Operators#

Regional programmes focus on specific geographic markets and often achieve strong local recognition.

EPD Norge (The Norwegian EPD Foundation) serves Nordic markets with particular strength in Norway. Construction products targeting Nordic countries benefit from EPD Norge’s market acceptance.

EPDItaly provides Italian-language service with strong recognition in Italian markets. Similar regional operators exist for Spain (GlobalEPD/AENOR), France (FDES/INIES), Turkey, and other regions.

EPD Australasia covers Australia and New Zealand markets with PCRs relevant to Southern Hemisphere conditions and building practices.

Regional programmes make sense when:

• Most of your sales concentrate in that region
• Local regulations or certification schemes specifically recognise that programme
• You want support in local languages
• Regional databases and conditions better represent your manufacturing

The tradeoff is potentially limited recognition outside the region. If you expand geographically later, you might need additional EPDs from other programmes.

Sector-Specific Programmes#

Some programmes focus on particular industries, developing deep expertise and detailed PCRs for their sectors.

Construction product programmes dominate EPD activity because regulatory and market pressure is strongest there. But programmes exist for specific sectors like electronics, furniture, food and beverage, and textiles.

Sector-specific programmes offer:

• PCRs tailored precisely to your product type
• Verifiers with deep industry knowledge
• Industry-specific guidance and templates
• Peer networks for collaboration

The limitation is that sector-specific programmes may have narrow recognition. If your products cross sectors or markets expand beyond the programme’s focus, broader programmes might serve better.

Key Selection Factors#

Several factors should drive your programme operator choice.

Market Recognition#

The most critical factor is whether your target markets recognise EPDs from this programme. Check:

Green building schemes. If you need LEED credits, verify the programme is in LEED’s approved list. For BREEAM, check BREEAM recognition. Different schemes maintain different lists.

Regulatory compliance. If regulations require EPDs, confirm the programme meets regulatory requirements. European construction regulations generally accept any ISO 14025 programme, but check specifics.

Customer requirements. If major customers or tender specifications mention EPD requirements, check which programmes they accept. Some specify particular operators.

Geographic markets. In Germany, IBU carries weight. In North America, UL is strong. Internationally, EPD International has broadest recognition. Match the programme to where you sell.

Don’t assume all ISO 14025 programmes are equally recognised everywhere. They’re all valid technically, but market recognition varies.

PCR Availability#

The programme must have a suitable PCR for your product, or be willing to support developing one.

Search the programme’s PCR registry for your product type. If exact matches exist, those programmes move to the top of your list. Creating EPDs under existing PCRs is vastly faster and cheaper than PCR development.

Check PCR currency. An outdated PCR might require updating before use. A recently revised PCR is ideal.

Evaluate PCR scope. Does the PCR cover your product precisely or just approximately? A generic PCR might technically apply but miss product-specific environmental aspects.

Assess harmonisation. Some programmes have mutual PCR recognition. An EPD created under one programme’s PCR might be acceptable to another programme with harmonisation agreements. This flexibility can be valuable.

If suitable PCRs don’t exist anywhere, choose a programme willing to support PCR development. This requires engaging the operator early to discuss feasibility, timelines, and costs.

Fee Structure#

Programmes charge various fees with different structures:

Registration fees for publishing each EPD. Typically £500-2,000 per EPD.

Annual fees for maintaining EPDs in the registry. Some programmes charge these, others don’t.

PCR fees if you’re developing new PCRs or using specialised PCRs. Usually separate from EPD fees.

Verification costs are generally independent of the programme operator but operators maintain approved verifier lists with varying rates.

Compare total costs over the five-year EPD validity period. A programme with low registration but high annual fees might cost more than one with higher registration but no annual charges.

For multiple products, check whether programmes offer volume discounts or package deals. Some provide reduced rates for manufacturers creating many EPDs.

Language and Support#

Programme operators work in different languages and provide varying support levels.

Primary language matters for navigating requirements, templates, and communications. If you’re not fluent in German, IBU’s German-primary operation might be challenging. International programmes typically operate in English.

Support responsiveness varies. Some programmes provide extensive guidance, answer questions quickly, and help navigate problems. Others maintain more hands-off approaches expecting manufacturers or consultants to figure things out.

Documentation quality affects how easily you can create EPDs. Clear guidance documents, good templates, and comprehensive FAQs reduce confusion. Some programmes provide excellent resources. Others are minimal.

Training availability. Some operators offer workshops, webinars, or training programmes helping manufacturers understand requirements. This education can be valuable for first-time EPD creators.

If you’re creating EPDs internally without consultant support, strong operator support becomes more important. If working with experienced consultants, operator support matters less because consultants know the systems.

Standards and Methodology#

Most programmes follow ISO 14025 and reference ISO 14040/44 for LCA methodology. But specific implementation varies:

Impact assessment methods. EN 15804 construction EPDs use European Commission methods. Other programmes might use TRACI, CML, or ReCiPe methods. Check that methods align with your needs and markets.

Module requirements. Some programmes mandate comprehensive life cycle coverage including Modules C and D. Others allow more flexibility. Check what’s required versus optional.

Data quality requirements. Programmes set different thresholds for primary data percentage, cut-off criteria, and database vintage. Stricter requirements mean higher quality but more data collection burden.

Verification stringency. All programmes require verification, but expectations vary. Some programmes have reputations for thorough verification. Others are perceived as lighter touch.

For technical buyers and sophisticated markets, programmes with stricter requirements carry more credibility. For markets where EPD presence matters more than details, flexibility might be preferable.

Programme Reputation and Longevity#

Programme operator credibility affects EPD value.

Established programmes with years of operation and hundreds or thousands of published EPDs carry more weight than new programmes with limited track records.

Programme governance matters. Is the operator an industry association, independent non-profit, government agency, or commercial entity? Each has implications for objectivity and continuity.

Financial stability. Programme operators need sustainable business models. Programmes that close or change ownership create uncertainty about EPD validity and access.

Industry relationships. Programmes with strong connections to manufacturers, customers, and building schemes can influence evolving requirements and standards.

Major established programmes (EPD International, IBU, UL) have proven track records. Newer or smaller programmes might be fine but warrant more due diligence.

Multi-Programme Strategies#

Some manufacturers create EPDs in multiple programmes to maximise market coverage.

When this makes sense:

• You sell into distinct geographic markets with different programme preferences
• Different customer segments require different programmes
• Regulations in different regions recognise different programmes
• You want maximum flexibility for future market expansion

The efficiency approach: Many EPD software tools can generate declarations conforming to multiple programmes from the same underlying LCA data. The core data collection and modelling happens once. Creating outputs for different programmes adds mainly verification costs and programme fees rather than repeating the entire process.

Some programmes have mutual recognition agreements letting EPDs from one programme be recognised by another with minimal additional work. Check whether these agreements exist between programmes you’re considering.

Cost-benefit calculation: Multiple EPDs mean multiple registration fees, verification costs, and maintenance burdens. Balance these costs against market access benefits. If 90% of your business comes from markets where one programme suffices, the incremental benefit of additional programmes might not justify costs.

Evaluating Specific Programmes: A Checklist#

When considering any programme operator, evaluate:

Recognition:

• Listed by relevant green building schemes?
• Accepted in your geographic markets?
• Recognised by your major customers?
• Meets applicable regulatory requirements?

Practical feasibility:

• Suitable PCR exists or programme will support development?
• PCR requirements match your data availability?
• Language and support adequate for your team?
• Verification services available in your region?

Costs:

• Registration fee per EPD?
• Annual maintenance fees?
• PCR access or development costs?
• Expected verification costs?
• Total five-year cost?

Technical fit:

• Impact assessment methods appropriate for your markets?
• Module requirements match your needs?
• Data quality requirements feasible?
• Standards alignment with customer expectations?

Operational factors:

• Support quality adequate?
• Documentation clear?
• Registry user-friendly?
• Programme stability and reputation?

Scoring these factors based on your priorities helps compare programmes systematically rather than making decisions on incomplete information.

Common Selection Mistakes#

Choosing based solely on lowest cost. The cheapest programme might not be recognised where you need it, creating false economy. Cost matters but recognition matters more.

Assuming all ISO 14025 programmes are equivalent. They’re all valid but they’re not interchangeable. Market recognition varies substantially.

Ignoring PCR availability. Discovering too late that suitable PCRs don’t exist delays projects massively. Check PCR registries early.

Not checking customer requirements. If major customers specify programmes and you choose differently, your EPD might not satisfy their requirements despite being valid.

Forgetting geographic expansion plans. Choosing a regional programme works well until you expand into markets where it’s not recognised. Consider future plans.

Getting Programme Operator Input#

Most programme operators are willing to discuss whether their programme suits your needs. Before deciding:

Contact operators directly with questions about PCR availability, recognition in your markets, and support for your product type.

Request fee schedules including all costs, not just registration fees.

Ask about timelines from submission to publication.

Check verifier availability in your region or for your product category.

Programme operators want suitable members. They’ll usually provide honest assessment of whether their programme fits your situation. If they’re not responsive during evaluation, expect similar support during EPD creation.

The Decision Framework#

Your programme operator choice should follow from:

1. Market requirements – Where do you sell and what do those markets recognise?
2. PCR availability – Do suitable PCRs exist in the programme?
3. Cost feasibility – Are total costs over five years acceptable?
4. Practical capability – Can you meet the programme’s requirements with available data and resources?

If multiple programmes satisfy these criteria, secondary factors like support quality, language, or personal familiarity can tip decisions.

For many construction product manufacturers, the choice is straightforward: EPD International for global markets or diverse customers, IBU for German focus, regional programmes for specific local markets, or multiple programmes for maximum coverage.

For other sectors or unique situations, more research may be needed. Engaging consultants who work across programmes can provide practical insights about which programmes work well for products like yours.

After Choosing: Committing to the Process#

Once you select a programme, commit to its requirements. Getting an EPD requires following the programme’s procedures, meeting its PCR requirements, and working with its approved verifiers.

Some programmes allow switching or creating additional EPDs in other programmes later. The LCA work transfers but you’ll need additional verification and registration. Factor this flexibility into long-term planning.

The “wrong” programme choice is one that doesn’t get recognised where you need it or costs far more than necessary. Beyond those extremes, most major programmes will serve you adequately. Choose one that fits your markets and get started rather than endlessly deliberating. The real value comes from having verified environmental transparency, not from theoretically optimal programme selection.