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Product carbon footprint or EPD: two different deliverables

A customer asks for "the carbon footprint of the product". Sometimes they want a verified CFP under ISO 14067:2018. Sometimes they want a published EPD under ISO 14025:2006, with a programme operator and a product category rule. The two overlap in method and diverge in almost everything else.

First published01 September 2026
Last technical review01 September 2026
Review cycleAnnually
AuthorTechnical Directorate, Energy Up International
Technical reviewCompliance and Accreditation Officer
Reading time9 min
Side by side

What each deliverable is.

Product carbon footprint (CFP)

ISO 14067:2018
  • A single impact category: climate change, expressed as CO2e per declared unit.
  • Built on the LCA framework of ISO 14040 and ISO 14044.
  • Cradle-to-grave by default; a partial CFP covers defined stages, such as cradle-to-gate.
  • Where a CFP-PCR exists for the product category, it applies.
  • Verified against ISO 14064-3:2019 and reported in a CFP study report.

Environmental product declaration (EPD)

ISO 14025:2006 · EN 15804+A2 for construction
  • A Type III declaration: multiple indicators, not climate alone.
  • Requires a programme operator and a product category rule (PCR).
  • Independently verified, then published in the programme register with a validity period.
  • Comparability between EPDs is only valid inside the same PCR and programme.
  • For construction products, EN 15804+A2 is the core PCR; ISO 21930:2017 applies for building works.
A CFP can exist without an EPD. An EPD cannot exist without a programme and a PCR — which is why an EPD has a lead time that a CFP does not.
Procurement

Which one does the requirement point to?

The requirement saysLikely deliverableWhat you also need
"Provide the product carbon footprint"Verified CFP to ISO 14067:2018A declared unit, a defined boundary, and a decision on cradle-to-gate versus cradle-to-grave
"An EPD is required for tender submission"Published EPD to ISO 14025:2006A programme operator, the applicable PCR, an LCA, and time for verification and publication
"EN 15804 compliant declaration"Construction EPD under EN 15804+A2Modules A1–A3 as a minimum, and the modules the client actually requires
"Scope 3 category 1 data from suppliers"Cradle-to-gate partial CFP per purchased productAlignment with the customer's allocation and boundary rules, or the data will not be usable
"CBAM embedded emissions"Neither — this is a regulatory calculationEmbedded emissions per Implementing Regulation (EU) 2025/2547, verified by a CBAM-accredited verifier
The last row matters. CBAM embedded emissions are calculated under EU rules with their own system boundary and their own precursor treatment. A CFP or an EPD is not a substitute for that calculation, and cannot be submitted in its place.
Sequence

The order that avoids rework.

  1. Name the user and the requirement

    Which customer, which tender, which framework, and the exact wording of the clause. Everything below follows from it.

    Before anything

  2. Fix the declared unit

    One tonne, one square metre, one unit of packaged product — with the function it delivers. A change here invalidates everything downstream.

    Definition

  3. Fix the boundary and the modules

    Cradle-to-gate or cradle-to-grave; for construction, which of the EN 15804 modules. State the cut-off criteria and the allocation rules.

    Boundary

  4. Build the inventory and the model

    Primary data for the foreground system; documented secondary data with database, version and geography for the background.

    LCA

  5. Independent verification

    Performed by a body that took no part in preparing the study. For an EPD, verification also has to satisfy the programme operator's own rules.

    Verification

  6. Publication or issue

    A CFP results in a verified study and statement. An EPD is registered and published with a validity period, after which it must be revised or withdrawn.

    Output

Primary sources

  1. ISO 14067:2018 — Carbon footprint of products: requirements and guidelines for quantification — www.iso.org/certification.html (checked 01 September 2026)
  2. ISO 14040:2006 and ISO 14044:2006 — LCA principles, framework and requirements — www.iso.org/certification.html (checked 01 September 2026)
  3. ISO 14025:2006 — Type III environmental declarations: principles and procedures — www.iso.org/certification.html (checked 01 September 2026)
  4. ISO 21930:2017 — Core rules for environmental product declarations of construction products and services — www.iso.org/certification.html (checked 01 September 2026)
  5. ISO 14064-3:2019 — verification requirements applied to product-level assertions — www.iso.org/certification.html (checked 01 September 2026)
  6. Commission Implementing Regulation (EU) 2025/2547 — CBAM methods for calculating embedded emissions — eur-lex.europa.eu/eli/reg_impl/2025/2547/oj/eng (checked 01 September 2026)

Editorial note. Author and technical review above are editorial functions. They are separate from the independent technical review and the decision functions required under ISO/IEC 17029:2019, which apply to validation and verification engagements and not to published articles. Nothing on this page is advice on a specific engagement, and nothing here extends or replaces the accreditation records.

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InsightCradle-to-gate or cradle-to-graveServiceProduct carbon footprint verificationEvidenceEPD records

Describe the claim — not the service.

Tell us what must be relied on, who will rely on it and by what date. We will confirm the correct programme, evidence requirement and responsible entity — or tell you it is outside our scope.

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