The trust gap in EPDs: why a verified declaration still may not mean verified data
An EPD tells a buyer your product’s environmental footprint. But here is the uncomfortable question more and more buyers are asking: how do you know the numbers behind it are true?
We hear it constantly. A manufacturer sends us their Environmental Product Declaration, a client pushes back, and the conversation lands on the same point: „This data is self-reported. Nobody checked whether it reflects what actually happens in the factory.” That instinct is correct — and it exposes a structural weakness in how most EPDs are produced today.
What „verified” usually means — and what it doesn’t
Under EN ISO 14025, a Type III EPD must be independently verified. That sounds reassuring, and it matters: an independent verifier checks that the Life Cycle Assessment follows the Product Category Rules, that the calculation method is sound, and that the declaration is internally consistent.
But here is the limit. In most cases, verification reviews the model and the methodology — not the truth of the primary data feeding it. The energy consumption, the bill of materials, the transport distances, the waste figures: these are typically taken from what the manufacturer reports. No one travels to the plant to confirm that the declared reference year, the declared recipe, or the declared energy mix is what really happens on the line.
This is not a fringe concern. It is being said out loud across the industry.
The industry is already worried about this
Verifiers themselves are raising the alarm. Across the sector there is growing concern that suppliers present EPDs built on unreliable environmental data — to the point that some verifiers hesitate to accept declarations whose underlying figures they cannot trace back to the plant.
The structural causes are well documented:
- The underlying rules are loose and open to interpretation, and there are no formal qualifications required to be an EPD developer.
- Verifiers are often paid by volume of verifications, with little incentive for deeper scrutiny.
- System-verified (automated) EPDs raise transparency concerns, because automated checks don’t apply the same rigour as a manual, expert review.
Academic work points the same way: the rapid growth in EPDs has „raised concerns about data quality assurance”, and current practice needs a more robust path to ensure it (Building and Environment, ScienceDirect).
The result is a quiet credibility problem: a declaration can be fully „verified” on paper, and still rest on data that no independent party has confirmed at source.
Why this is about to matter more: System 3+
Europe’s new Construction Products Regulation (Regulation (EU) 2024/3110) introduces a verification system known as System 3+. Under it, the environmental data behind a product’s Declaration of Performance is independently validated — not just methodologically reviewed — on the principles of EN ISO/IEC 17029, the standard for validation and verification bodies.
In plain terms: System 3+ pushes the assurance down to the data itself. It is the regulatory recognition that „trust me, these are my numbers” is no longer enough. The direction of travel is clear, and buyers are already moving ahead of the regulation.
What manufacturers can do now
You don’t have to wait for the regulation to bite. If your buyers are challenging your data, the answer is to raise the assurance level of your declaration — voluntarily, today:
- For construction products under the CPR: move from desktop readiness toward on-site verification of your primary data, aligned with System 3+ logic. See the EPD+ assurance levels.
- For products outside the CPR (furniture, finishes, chemicals, non-construction goods): there is no Declaration of Performance, but a voluntary, independently validated EPD+ for non-CPR products gives your buyers the proof a self-declaration can’t.
The point is not that EPDs are worthless — far from it. The point is that not all assurance is equal, and the market is starting to tell the difference. A declaration whose data has been checked at the source is a fundamentally stronger document than one that hasn’t.
Frequently asked questions
Isn’t every EPD independently verified already?
Type III EPDs under EN ISO 14025 are independently verified, but verification usually focuses on the LCA model and methodology — whether the calculation follows the Product Category Rules. It does not, in most cases, include an on-site check of whether the manufacturer’s reported primary data (energy, materials, transport) is accurate at the source.
What is the difference between EPD verification and System 3+ validation?
Standard verification confirms the declaration is methodologically correct. System 3+, introduced by CPR 2024/3110, adds independent validation of the environmental data itself, on the principles of EN ISO/IEC 17029. It moves the assurance from „is the maths right” to „is the input data trustworthy”.
My product is not a construction product. Does any of this apply?
Yes. Products outside the CPR have no Declaration of Performance and no harmonised standard, yet buyers still demand environmental data. A voluntary EPD+ to EN ISO 14025, independently validated, is the credible alternative to a self-declared claim.
EPD+ is the high-assurance layer operated by Multicert under the EPD Poland programme. If your buyers are questioning your data, talk to us about raising your assurance level.