FAQ

EPDItaly REGULATION

 

R.For greater clarity regarding the role of the EPD Owner:
The EPD Owner is the legal entity holding full responsibility and ownership of the EPD. They are responsible for the accuracy and correctness of its content, for submitting the publication request, and for keeping the EPD up to date. The EPD Owner ensures that the product complies with applicable environmental and safety regulations.
They are also responsible for preparing or supervising the LCA Report and for collecting the necessary data, maintaining full responsibility even in cases where these tasks are delegated to third parties.

R. Any significant differences concerning the average between products and/or production sites must be declared and justified in both the LCA Report and the EPD.
This applies to the maximum deviation (declaring both maximum and minimum values) for all environmental impact indicators (excluding indicators related to resource use and waste/output flows based on the LCA ) referring to the entire life cycle, excluding Module D, or in any case to all life cycle modules considered in the EPD (except Module D).

Operational note:
We remind that in the case of average EPDs, only the LCA Report must include the calculation of the maximum deviation of the environmental indicators with reference to the total value of all the life cycle modules considered (except module D). Conversely, in the EPD, it is sufficient to declare the maximum deviation of the identified product for each environmental indicator.
For example: the total GWP shows a maximum deviation of +35% and a minimum deviation of –25%, etc.  Furthermore, it is recommended to include in the EPD additional explanations regarding the aspects influencing the deviations and the products showing the maximum and minimum impacts.  Finally, please note that the LCA report must also justify any deviations ≤ 10%.

R.Mass balance approaches (MBA) and/or “Book and Claim” methods, as per ISO 22095 (e.g., biomass balance (BMB) or allocation/attribution approaches for recycled content), must not be used in relation to ECO EPDs.
The Annex for Electricity and Biogas Rules applies. This approach must be extended to all EPDs published under the EPDItaly Programme Operator.

R.CH – 1.1.1
For greater clarity, concerning compliance with the requirements under points b) and f), these will be met by including in the EPD the identification of products and values as indicated by the specific product certification Regulation/Disciplinary referred to in the previous point e), or as shown in the following table. See Table – Annex 7 – Reg. EPDItaly Rev. 7.1.

Compilation notes:

CH – 1.1.2
With regard to compliance with the requirements under points b) and f), these will be met by including in the EPD the identification of products and values as indicated in the certificate issued by the certification body.

R. For a product with multiple sizes or formats, this refers to a product whose environmental impact values are expressed based on a declared unit (e.g., mass, area, density, etc.), where permitted by the applicable PCR, in such a way that they remain independent of the different sizes or formats of the product itself (e.g., 1 m² of tiles; 1 ton of steel products; 1 ton of clay blocks).

In this case, the specific product EPD must:
– Explicitly state the commercial name of the product on the “Cover Page”;
– Indicate a Content Declaration that is the same for all sizes or formats of the product, as it is based on the same Bill of Materials;
– List all available sizes or formats of the product in the “Product Description”;
– Allow for the identification of the environmental impact values associated with each specific size or format of the product, providing appropriate conversion factors relative to the declared unit used.

It is clarified that in a specific product EPD, which in accordance with the EPDItaly Regulation may contain up to 10 datasets of environmental impact indicators, each referring to a different product, this product may also be one with multiple sizes or formats.

 

R. Yes, provided that the specific address is included in the LCA Report and made available by the Organisation, following a request by a third party applicant and evaluation by the Certification Body, for purposes related to the use of the EPD document itself.
This aspect is inherent to one of the requirements introduced and dealt with in the EPDItaly Regulation in version 5.3, which has recently completed the public consultation phase without receiving opposing opinions.

 

R. The reference product is to be understood as a product belonging to the initial product cluster or notional product (clearly defined in its technical characteristics).

 

R. In case the EPD Owner is manufacturer or distributor/importer:

Case A) the EPD Owner is the “manufacturer” if the product is manufactured directly or is manufactured by another party on behalf of the EPD Owner (toll manufacturing). In this case the impacts of the product manufacturing processes are considered in the Core Module.

Case B) the EPD Owner is a distributor/importer when the product is not manufactured directly by the EPD Owner but is manufactured and placed on the market by another entity and purchased by the EPD Owner In this case, in the Core Module the manufacturing processes of the product are not considered but the processes actually under the control of the EPD owner (e.g. logistics, packging distribution, etc.) are considered. In Upstream, the impacts of the product manufacturing processes supplied are considered (use of secondary data or possible use of data collected by the EPD Owner from the specific supplier) as for any other material supply.

 

R. The reference product is to be understood as a product belonging to the initial product cluster or notional product (clearly defined in its technical characteristics).

 

R. Since February 2023, the EF 3.1 method adopted by the EN 15804 standard is available at the following link: https://eplca.jrc.ec.europa.eu/LCDN/EN15804.xhtml

EPDItaly defines a transition period of 1 year, until 29 February 2024, to allow an alignment of the LCA software market, in which it will be possible to develop and validate EPDs using the old version (based on EF 3.0) or the new version (based on EF 3.1), declaring it in the EPD.

EPDItaly’s position will be reviewed when the transition expires.

 

PCR

R. Within the PCR “EPDITALY029-sub-PCR – Cement, binders and READY-MIXED COMPONENTS_REV.1.1”, the term “READY-MIXED COMPONENTS” refers to mixtures of components, essentially comparable to binders, that do not contain water, aggregates (such as sand or other inert materials), and additives required to form the derived product. Since the definition provided in the document may not be entirely explicit, it is expected that this specification will be further clarified in a future revision of the PCR, in order to ensure a consistent and unambiguous interpretation among different industry operators. At present, since there is no specific sub-PCR available that comprehensively covers products such as mortars, plasters, etc., that is, products containing an inert (aggregate) component, it is necessary to refer to the Core PCR “PCR ICMQ-001-15”, which serves as the general reference document for these types of products.

R. The PCR in question defines the application for products falling under CPC family code 46: “Electrical machinery and apparatus”.
Although , “Electro-diagnostic apparatus, used in medical, surgical, dental or veterinary sciences” do not fall under this family, but under CPC code 481 “Medical and surgical equipment and orthopaedic appliances” following in-depth analysis with experts in the field , we believe that CPC Code 481 can be included in the scope of PCR 007, where “Medical and surgical equipment and orthopaedic appliances” refers to electrical products. For this reason, the document will be revised in the future. In the transitory period, however, it is possible to develop an EPD that also references the PCR for “Electro-diagnostic apparatus, used in medical, surgical, dental or veterinary sciences” , provided that these are electrical/electronic products .

 

R. Compared to EN 15804, additional requirements for an EPD of construction services are to be introduced: the inclusion of modules A4 and A5 is mandatory in addition to modules A1-A3; C1-C4; D, in accordance with the common rules of other Programme Operators. This additional requirement will be regulated in the future revision of the Core-PCR of Construction Products.