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. 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.



R. The PCR in question excludes the use of methane gas systems, however it does not exclude the use of hybrid systems.
This is why the PCR will be revised with the introduction of such appliances. In the transitional period, an EPD can be developed with the PCR as a reference and describing for transparency the methodology adopted for calculating the methane gas contribution.


R. The PCR in question clearly defines the application of the PCR for “Three-phase transformers and autotransformers in naturally-cooled oil”, however it does not exclude the use of the same PCR for other types of transformers, as indicated in Chap. 1.4 – “In case the LCA covers a transformer not included in the clusters shown in table above, the EPD owner shall choose the most appropriate classification according to operating parameters of the equipment.” Therefore, following in-depth analysis with industry stakeholders on the need to expand the scope of the PCR, the document will be revised with the introduction of such equipment. In the interim, it is possible to develop an EPD that will also refer to the PCR for “Resin Transformers”, maintaining the requirements of the PCR (Technical Characteristics, RSL; Use Phase Formula).


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.