EPD can be published as translation to several languages, but the publication needs to be done either in Finnish or in English.
The publication fee is the only fee that you pay to Building Information Ltd for the publication of an EPD. The EPD is valid for five years (pre-EPD is for one and half year). There are no annual fees or similar continuous charges. If the data changes so much that it needs reapproval from the technical committee, there is a charge on that.
It is possible to report more than one product with one EPD. This can be done either with several result tables or with a set of scaling factors (for example different dimensions of the same material). If there are several products in one EPD, the readability can suffer, and one choice is to publish more than one EDP document from the same study and background report. If you are wondering, please, contact us at epd@rakennustieto.fi .
Cases where for example there are changes in the process equipment, raw material or energy source (for example from national average to green energy) that change the GWP total A1-A3 is more than ±10 % (as said in the EN 15804: “An EPD shall only be reassessed and updated as necessary to reflect changes in technology or other circumstances that could alter the content and accuracy of the declaration”). In these cases, there might be several changes in the indicator tables, but the validity dates remain the same and it is considered as one approval in the technical committee.
cases where for example theamount of recycled material changes in raw material (as said in the EN 15804: “An EPD shall only be reassessed and updated as necessary to reflect changes in technology or other circumstances that could alter the content and accuracy of the declaration”). In these cases, there might be several changes in the indicator tables, but the validity dates remain the same and it is considered as one approval in the technical committee.
During the five years validity time there can happen a lot. For example new contact persons and contact details, changes in company or product names. This type of update is done free of charge, at the moment.
If the products are from the same production site and the differences are quite small between the products, you have some options.
a) The first option of grouping is that you calculate and declare an average of the products. This way the allocation for example electricity on the production and the amount of side products is minimal, sometimes those are measurable only at the production line or even at the site level (A1-A3 GWP total needs to be within ±10 % in this case).
b) The second option would be to choose a representative product and calculate all production by that and state in the EPD the reason this has been selected (for example ‘this product is XX % of all production’). This already needs some more allocations, and the results should be within ±10 %.
c) One possible option could be to use the worst-case of all products (by selecting the worst values for each indicator), this can also include higher variation of results.
EPD can follow graphical guidelines of company or from the tool. The contents of the EPD are defined in the standard and in the PCR document, but the graphical design can be chosen freely. Sometimes the EPD goes through graphical design after it has been approved to be published.
It is possible to publish an EPD for a private label product*) based on the EPD for the original manufacturer of the product. The EPD of the original / branded product needs to be published by us in Rakennustieto and the private label EPD will share the same expiration date. For the private label EPD we give a discount on the publication fee.
*) A private label product means a product that is manufactured (and quite often marketed as original brand) by another company than yours.
MBA is not allowed to be used in the Environmental Product Declarations at the moment. There is not yet consensus over the issue and discussions are ongoing in both CEN TC350 WG3 and ECO Platform about this. You can read more about this from the ECO Platform position statements https://www.eco-platform.org/position-statements.html
Mass balance approach means calculation, in which some raw material flows with specified characteristics (for example recycled content, biobased material etc.) of a product are allocated to the products not by the tracked average content nor by the tracked physical content at the moment of the production but on a theoretical basis, resulting part of the production with a higher content than would be possible otherwise. This theoretical basis is called the “mass balance model: credit method” in ISO 22095, which describes various chain of custody approaches.
Here is an example how MBA works: a site has, as an example, only 5% of its input with the specified characteristic which physically is actually spread across all products equally. Using the MBA it would be possible to allocate this 5% theoretically so that 5% of its production has 100% of the specified characteristic, and 95% of the production has 0% of the specified characteristic.
Scenario 1: Wooden pallet/wood-based packaging enters into the system under study as a new pallet and is to be re-used as a packaging material:
When it enters the system (in A3 as packaging), the packaging carries 100% of all burdens of the manufacturing of the pallet. It has full biogenic CO2 content (-kgCO2e) and full renewable energy content (+MJ).
As it exits the system in A5 (as a packaging to be reused), it releases the entire biogenic CO2 content (+kgCO2e) and the full renewable energy content needs to be balanced here (-MJ) as Primary Energy resources (PER) used as material. Also the transport to the next use should be here.
In module D of the EPD it should show the net benefits of pallet which will replace a new pallet and also some burdens from the repair of the earlier used pallet to replace a new pallet are included (0-5% from burdens of manufacturing of a new pallet, thus resulting at least 95% savings for manufacturing for the next life cycle).
Scenario 2: Wooden pallet/wood-based packaging enters into the system under study as a new pallet and is to be recovered by its energy content in the next life cycle:
When it enters the system, the packaging carries 100% of all burdens of the manufacturing. It has full biogenic CO2 content (-kgCO2e) and full renewable energy content (+MJ).
As it exits the system in A5, it releases the full biogenic CO2 content (+kgCO2e) and the full renewable energy content needs to be balanced here (-MJ) as Primary Energy resources (PER) used as material (chipped for recovery). The transportation to the energy recovery and burdens from the chipping/other processing belong to here.
In module D of the EPD, it should show the net benefits of energy recovery. The full Biogenic CO2 content (expressed as -kg CO2eq/kg) is inherited again back to wood material, meaning that the release of Biogenic CO2 content in energy production will be resulting net zero Biogenic CO2 emissions.
If there is a share ending to landfill (i.e. pieces broken beyond reparation), similar reasoning as in scenario 2 applies.
The so called "1/10" rule is from PEF method, it is not in line with EN 15804+A2, meaning that all impacts from manufacturing of e.g. a new wooden pallet should be addressed to it = i.e. attributional LCA/cut-off approach.
Scenario 1: Wooden pallet/wood-based packaging enters into the system under study as re-used and is to be re-used again as a packaging material in the next life cycle:
When it enters the system, the packaging carries 0-5% of all burdens of the manufacturing (the possible repairs, see question about new packaging). It has full biogenic CO2 content (-kgCO2e) and full renewable energy content(+MJ).
As it exits the system in A5 (as a packaging to be reused), it releases the full biogenic CO2 content (+kgCO2e) and full renewable energy content needs to be balanced here (-MJ) as Primary Energy resources (PER) used as material. Also the transport to the next use should be here.
In module D the EPD should show only minor benefits of the reused pallet which will replace a re-used pallet and also some burdens from the repair of the earlier used pallet to replace new pallet are included (0-5% from burdens of manufacturing of a new pallet).
Scenario 2: Wooden pallet / wood packaging enters into the system under study as re-used and is to be recovered by its energy content in the next life cycle:
When it enters the system, the packaging carries 0-5 % of all burdens of the manufacturing. It has full biogenic CO2 content (-kgCO2e) and full renewable energy content (+MJ).
As it exits the system in A5, it releases the full biogenic CO2 content (+kgCO2e) and full renewable energy content needs to be balanced here (-MJ) as Primary Energy resources (PER) used as material (chipped for energy recovery). The transportation to the energy recovery and burdens from the chipping/other processing belong to here.
In module D the EPD should show the net benefits of energy recovery. The full Biogenic CO2 content (expressed as -kg CO2eq/kg) is inherited again back to wood material, meaning that the release of Biogenic CO2 content in energy production will be resulting net zero Biogenic CO2 emissions.
If there is a share ending to landfill (i.e. pieces broken beyond reparation), similar reasoning as in scenario 2 applies.
Quite often companies use an LCA practitioner on the EPD project. The tools usually used in the LCA are not on open access and it is not trivial to use them at the first time. We at Rakennustieto have a list of LCA practitioners we have worked with, but it is not comprehensive.
It is good to select the publisher already in the beginning, so that the instructions given in the Product Category Rules (PCR) can be followed from the start. The PCR documents give more specific instructions than the standard, as the standard needs to be so general that it works in all the situations with all possible products. Quite often the PCR contains instructions about the possible scenarios to use in some situations (like transportation on module A4 or on the energies to use in the calculations).
After the LCA is ready, the EPD itself and a project report are prepared from the LCA. The project report is for the verification and it is not published but used by the verifier to see the quality of the data sources and that the standard and PCR are followed.
After the verification the EPD (and accompanying documents) are sent to us via application portal for publication. We at Rakennustieto make a final check on the EPD before publishing it on our website and on the ECO Platform.