What EPD Verifiers Actually Look For: 5 Things First-Time Practitioners Often Miss
Are you producing your first Environmental Product Declaration (EPD) but not sure what EPD verifiers actually look for?
Are you wondering whether you've done enough to get your EPD through EPD verification? Or perhaps you've already received questions from an EPD verifier and aren't sure what needs to be improved. Maybe you're wondering why your Environmental Product Declaration (EPD) wasn't approved the first time.
Many first-time LCA practitioners discover that EPD verification is about much more than checking calculations. In fact, many of the issues raised during the EPD verification process aren't calculation errors, they're practical decisions around methodology, data quality, interpretation and documentation.
If you want to make the EPD verification process less daunting and gain more confidence in producing a verification-ready EPD, keep reading to better understand what EPD verifiers are actually looking for.
1. EPD verification starts earlier than most people think
Did you know that experienced EPD practitioners often contact the EPD verifier before the Environmental Product Declaration (EPD) is finished?
A common misconception is that EPD verification only begins once the Life Cycle Assessment (LCA) has been completed and the EPD has been written.
That can feel counterintuitive at first. After all, if the declaration isn't complete, what is there to discuss?
In reality, experienced practitioners know that some methodological decisions need to be agreed before carrying out significant modelling work.
Seasoned practitioners start these methodology discussions early to reduce uncertainty during the EPD verification process and avoid unnecessary rework later in the project.
For example, a manufacturer may want to represent several similar products using a single LCA model by applying linear environmental impact variability. Some EPD verifiers may not be comfortable with that approach and may instead require a different methodology or ask for additional justification.
If those discussions happen late in the project, they can result in significant rework and delays to the Environmental Product Declaration (EPD). Agreeing on the methodology early is much easier than revisiting it after the EPD has been completed.
That's why experienced practitioners think about EPD verification from the very beginning, ensuring that key methodological decisions are aligned with the EPD verifier. It's one of the practical habits that helps produce a verification-ready EPD while reducing time, uncertainty and unnecessary revisions.
Do you want to explore this further? If you're currently preparing an EPD and want to understand some of the common issues that can lead to delays, rework or challenges during verification, we explore these in more detail in our free webinar, Why EPD Projects Fail.
2. Data hierarchy matters more than most people realise during EPD verification
Not paying enough attention to data hierarchy is a mistake many first-time EPD practitioners make, often underestimating the importance of where their data comes from during EPD verification.
In reality, experienced practitioners know that data quality and correct modelling decisions are just as important as the calculations themselves.
For example, Module D often generates discussion during the EPD verification process.
One thing that often surprises first-time EPD practitioners is that recycled material doesn't automatically qualify for environmental credits. Whether those benefits can be claimed depends on how the material has been modelled and where it sits within the product's life cycle.
After participating in more than 500 EPD verifications, Matthias Schulz, one of the teachers in our EPD training, consistently comes back to one key principle:
"The heart of every LCA and EPD is the data."
That's why experienced practitioners place significant emphasis on data quality throughout the LCA modelling process.. In practice, this means assessing where the data comes from, selecting the most representative data available, checking whether it is plausible, confirming that the background datasets are appropriate, and ensuring that the data quality meets the requirements of the Environmental Product Declaration (EPD) and the relevant Product Category Rules (PCRs).
When selecting data for an EPD, a recognised data hierarchy generally follows this order:
Primary data from your company's own manufacturing processes, whenever available.
Industry-average data when company-specific data is not available.
Generic database data when neither company-specific nor industry-average data is available.
Ultimately, high-quality data is one of the foundations of a verification-ready EPD. During EPD verification, verifiers don't just assess the LCA model and its results: they also evaluate whether the data is appropriate, representative, and sufficiently robust to support the results.
3. Tool-based EPDs aren't verified the way many people expect
A common misconception is that EPD verification becomes automatic if the software or integrated EPD tools used to create an Environmental Product Declaration (EPD) have already been verified.
Experienced practitioners know that's not the case. If EPD software or integrated EPD tools are used to create an EPD, the EPD verification process changes and is carried out differently from a traditional project.
For example, the software itself may undergo extensive verification, with sample declarations reviewed periodically under ECO PLATFORM guidance.
Regardless of the tools used, the quality of the Environmental Product Declaration (EPD) and its likelihood of passing EPD verification still depends on the decisions made by the practitioner.
Experienced practitioners view software as something that supports the process, not something that replaces professional judgement. The practitioner is still responsible for decisions such as:
which data to use;
how to interpret the Product Category Rules (PCRs); and
how to justify and document modelling assumptions.
These are decisions that software cannot make on your behalf.
So, while EPD software and integrated tools can make producing an Environmental Product Declaration (EPD) more efficient, they don't replace the need for a robust methodology or the skills and knowledge of an experienced EPD practitioner. Successful EPD verification still depends on the experience and decisions of the practitioner, not the software alone.
4. EPD verification is also about interpreting the Product Category Rules (PCRs) correctly
Many first-time EPD practitioners assume that once the Life Cycle Assessment (LCA) has been completed, most of the difficult work is done, believing that EPD verification focuses primarily on writing a report in the right format, using an EPD template.
In reality, skilled practitioners often spend just as much time working through the Product Category Rules (PCRs) as they do building the model itself.
Why?
That's because the PCR isn't simply a set of rules for writing a report. It defines much more, including:
System boundaries and life cycle stages: which processes and life cycle stages need to be included;
Data quality and primary data requirements: what types of data need to be collected and how data quality should be assessed;
Declared unit and functional unit: how the product needs to be quantified and reported, for example per tonne, per m² or per unit;
Technical characteristics: which product properties need to be disclosed in the Environmental Product Declaration (EPD);
Impact categories and indicators: which environmental impacts need to be calculated and reported;
Assumptions and additional information: what needs to be explained and documented; and
Reporting structure: how information should be organised and presented in the EPD and accompanying project report.
That's why EPD verifiers don't just review the calculations. A key part of the EPD verification process is checking whether the Product Category Rules (PCRs) have been interpreted and applied correctly. Understanding and applying the PCR consistently is one of the foundations of producing a verification-ready EPD.
5. Transparency matters just as much as the numbers in EPD verification
As we've seen in Point 2, checking where your data comes from is just as important as how it is used in the LCA model.. The same principle applies throughout the EPD verification process, particularly when documenting assumptions for life cycle modules. Being transparent about how you arrived at your assumptions is just as important as the assumptions themselves.
One thing that often surprises first-time EPD practitioners is that practitioners need to spend a significant amount of time documenting those assumptions. For an EPD verifier, understanding how you arrived at an assumption is often just as important as the assumption itself.
Transport distances, logistics, end-of-life scenarios and recycling routes cannot always be measured directly. In many cases, they require informed assumptions based on the available Life Cycle Assessment (LCA) data and the relevant Product Category Rules (PCRs).
As Matthias Schulz points out in our EPD training, assumptions and limitations are one of the most common topics discussed during the verification process:
"Assumptions and limitations must be clearly identified and transparently described."
It's one of the practical habits that separates experienced EPD practitioners from those producing their first Environmental Product Declaration (EPD). Beyond the assumption itself, EPD verifiers want to understand how it was developed, whether it is justified, and whether it has been documented clearly enough for someone else to follow the reasoning.
When reviewing life cycle modules such as A4 through D, experienced practitioners often ask themselves:
✅ Can someone clearly understand how this assumption was developed?
✅ Is the reasoning clear?
✅ Is it documented thoroughly?
✅ Is it justified?
Clear documentation gives EPD verifiers confidence that the results can be understood, reviewed and traced back to the assumptions and decisions behind them. It's one of the key characteristics of a verification-ready EPD and can make the EPD verification process smoother and more efficient.
We hope this article has helped remove some of the mystery around the EPD verification process.
If you already have a solid understanding of LCA and a product LCA to work with, but you're feeling unsure about how to take it through the EPD development and verification process, our EPD training is designed to help you take that next step.
You'll have the opportunity to spar with experienced EPD practitioners and verifiers while working towards your first EPD draft, so that you can develop the practical skills and confidence to create EPDs more independently.
