This is a guide about what manufacturers need to know about Lifecycle Assessment (LCA) and Environmental Product Declaration (EPD) requirements in 2023 and how they should prepare if they make high-risk products or components (construction materials, textiles, lithium batteries…) to be sold in the European Union.

Author: Clive Greenwood, compliance consultant, 28 Nov. 2022

1. What is an Environmental Product Declaration?

First, an LCA is an assessment of the total environmental impact that comes from the entire life cycle of a product. We wrote about it at length in this article about LCAs.

An EPD (Environmental Product Declaration) is relatively close to an LCA, but it is a compliance declaration. It is a verified document that is registered with the government. It communicates transparent and comparable information about the life-cycle environmental impact of a product, not only to your customers but to the regulators and the general public in the EU member states (or the UK).

The EPD will be used to assess your commitment to, and understanding of a number of regulations and EN standards such as:

  • EN 15804:2012+A2:2019, Sustainability of construction works – Environmental product declarations – Core rules for the product category of construction products
  • EN 15643-1:2010, Sustainability of construction works – Sustainability assessment of buildings – Part 1: General framework
  • EN 15643-2:2011, Sustainability of construction works – Assessment of buildings – Part 2: Framework for the assessment of environmental performance
  • EN 15978:2011, Sustainability of construction works – Assessment of environmental performance of buildings – Calculation method
  • CEN/TR 15941:2010, Sustainability of construction works – Environmental product declarations – Methodology for selection and use of generic data
  • EN 15942:2011, Sustainability of construction works – Environmental product declarations – Communication formats: business to business
  • EN 16485:2014, Round and sawn timber – Environmental Product Declarations – Product category rules for wood and wood-based products for use in construction
  • EN 16449:2014, Wood and wood-based products – Calculation of the biogenic carbon content of wood and conversion to carbon dioxide
  • ISO 14025:2010, Environmental labels and declarations – Type III Environmental declarations – Principles and procedures (identical to ISO 14025:2006)
  • ISO 21930:2017, Sustainability of construction works – Environmental declaration of building products (as referenced by EN 15804 see V1.2)
  • ISO 14040:2006, Environmental management – Life cycle assessment – Principles and framework
  • ISO 14044+A1:2018, Environmental management – Life cycle assessment – Requirements and guidelines
  • PD CEN/TR 16970:2016, Sustainability of construction works. Guidance for the implementation of EN 15804.

In addition, the new Eco-design for Sustainable Products Regulation (proposal published in 2022, and final & detailed text to be enforced starting in 2025) will make it increasingly unlikely that products that do not meet the regulations will be permitted to be imported to the EU (among others, each product will have a “product passport, as we explain lower in this document).

Who is affected? Well, the debate continues, but our reading is down to two factors: one the design authority and secondly the person that makes the product available to the market. The first is easy to understand — it is the party the designed the product. The second takes some legal understanding.

Making the product available to the market is in its basic form anyone including web sites sales, the regional legal representative in terms of the CE mark, the actual importer of record, the buyer, and finally the manufacturer.

2. What goes into an EPD?

First, a lifecycle inventory.

The requirement is that you look at your product in the eyes of its entire life – this is often called ‘Cradle to Grave’ (or Cradle to Gate” for manufacturers if they are not the ‘design authority’). It means you look at the product from its extraction of raw material such forestry, mining, drilling, quarrying, or other processing, then on to the environmental impact of these actions.

You must then seek to answer, ‘what are the conditions or risk to the environment of transporting those materials to processing and beyond?’, and in addition ‘how is it processed, what chemical toxins are used, how does this affect not only the land but also the water table, animal habitat, air quality, and so on?’. All these questions are important.

We then turn to the amount of energy resources: are they fossil fuel, or renewable such as wind, wave, or solar?

Let’s take steel products as an example. The details you will need to gather are listed below:

  1. The type of steel (different steels have different processes and use more or less energy)
  2. The environmental impact of extraction
  3. The environmental impact of the processing, from melting the ore to the finished steel roll
  4. The amount of electricity, gas, coal, water used (typically, LCA software can evaluate that from your answers above, and from the number of tons you purchase)
  5. The fuel used in transporting the rolled steel to your factory.


The amount of energy you use in your production into your product:

  1. Your effect on the environment
  2. How much Gas, Water, Electricity you use in your production and how that power is generated
  3. A list of all toxic chemicals used in your production, and indications of how you ensure that you do not pollute both the air and ground water (treatment of toxic waste)
  4. What is the waste of raw material and how much % is recycled; and then:
  5. How much energy is used to recycle the waste; and finally:
  6. How much of the finished product can be recycled and by what means.

Environmental damage resulting from your products

environmental damage resulting from your products

Now, you may be thinking “but we are only one of the nodes in this whole chain”.

However, what happens in your supply chain is under your control or at least your influence!

3. The important concept of design authority

The amount of control or influence you have depends on who designed the product. If you have the design authority, then you have control over the product and thus the liability under the EU’s Eco-design for Sustainable Products Regulation and international standards such as EN 15804:2012+A2:2019 and ISO 14044:2006+A1:2018, to ensure that you have considered the damage it does to the environment.

client and supplier design authority effect on sustainability

However even if you buy a standard product, where you do not have design authority yet you have made the product available to the market, you still have regulatory requirement liability to ensure that your supplier has conducted the assessment and that you have had the analysis verified by independent audit.

A common remark by manufacturers is “we do not have knowledge of the product after we sell it”. However, an increasing number of assurance standards require a degree of post-market surveillance, which means it is the manufacturer’s responsibility to gain such knowledge. It is also their responsibility, through environmental risk and impact studies, to design products which meet environmental impact targets.  

4. Extraction of raw materials

The environmental impact of mineral or raw material extraction depends on the very material being extracted and on the method of extraction. For example, deep-mine coal extracting has a limited environmental impact while open-cast mining does. However, the use of coal is by far a major polluter. Conversely, the use of wood has few pollutants but massive environmental damage such as deforestation and loss of natural habitat, and soil erosion being a major environmental impact on many avenues.

Here is an example of the various environmental impacts of deep mining.

the environmental impacts of deep mining

5. Processing of raw materials

The products made from extracted raw materials are by far the largest pollutants over the actual material from which they are made.

For example, lithium ore requires large amounts of energy, from diesel to transport the ore, to gas or electricity to process the ore into cake, and then again energy is used to process the cake into battery cells, and finally, the cake is transported over huge distances from the mine to the processing plants (in some cases thousands of miles).

Plastics, especially microplastics, are seen as the biggest challenge to the oceans around the world, with environmentalists claiming that by 2050 there will be more plastic in the sea than fish.

For many years, the challenge of economics over environmental concern has been the only concern, with the deployment of important principles (eco-design, sustainability, circularity) seeking to address this by regulation over voluntary self-management in the supply chain.

In most general terms every raw material is modified by working the raw material into another form, trees become furniture, oil becomes plastic, coal, or gas becomes fuel to generate heat, iron ore becomes steel, the common factor is energy is used, you must know which type and how much!

6. Further reading


We at Sofeast are not lawyers. What we wrote above is based only on our understanding of the regulatory requirements. We do not present this information as a basis for you to make decisions, and we do not accept any liability if you do so. Please consult a lawyer before taking action.

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