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REGULATIONS OF

THE EPDItaly PROGRAMME

Issue date 03 /06 / 2019

Revision 4.0

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Date Rev. Status Publication date Notes

08/05/2015 0 Published 01/09/2015 First issue

10/11/2015 1 Published 23/11/2015 Modified to better explain compliance with EN 15804

15/02/2016 2 Published 11/04/2016 Corrected various minor errors and better explained the processing methods, both of waste and of the CO2

incorporated in the construction products

23/02/2017 3 Published 11/04/2017 Better explained the ways to create PCRs, the types of EPD and the respective verification methods.

Introduced Annex 1 with EPD format

11/04/2017 3 Draft Not published Copy for internal use, used for EPDItaly accreditation scheme

31/07/2017 3.1 Published 05/09/2017 Better explained the Program Operator’s tasks. Defined the methods adopted by the Certification Body to

maintain, renew, extend and reduce the EPD. Introduced the option of inserting into the EPD, the

TRACI characterisation factors within the scope of the mutual agreement for recognising EPDs.

Accepted some post public consultation comments

29/09/2017 3.2 Draft Not published Copy for internal use, used for accreditation by the Certification Bodies.

Modified list of the types of EPD and introduced some specifications on Non-Conformities discovered in the

audit phase.

Defined the Advisory Board’s expertise for Certification Bodies

19/10/2017 3.3 Draft for public consultation

// Introduced Annex 2 containing the requirements for Certification Bodies.

Accepted modifications from version 3.2

Better explained some statements

Better explained the methods to verify and maintain EPDs

25/11/17 3.3 Published 27/11/17 Following comments, introduced paragraph 2.26 into Annex 2 and corrected some editorial errors. Better explained how to manage the expiry of the validation certificate.

16/10/18 4.0 Draft Not published Copy for internal use, used for accreditation by the Certification Bodies, related to EPD-tool.

09/11/18 4.0 Draft for public consultation

Not published Clarifications about audit for EPD generated by LCA-tool and clarification about EPD-tool qualification. Creation of Annex 3 and Annex 4

21/11/18 4.0 Draft for public consultation

Not published IVA.3.5 insert

17/01/19 4.0 Draft Not published Update after Accredia’s audit

03/06/19 4.0 Published correction of a typo after public ocnsultation

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T a b l e o f C o n t e n t s

Table of Contents ................................................................................................................................................... 3

Introduction ............................................................................................................................................................. 4

Organisation ............................................................................................................................................................ 6

PCR development ................................................................................................................................................... 9

The EPD Declaration .......................................................................................................................................... 14

EPD Development and Verification ................................................................................................................. 20

EPD Publication process ..................................................................................................................................... 28

EPDItaly logo ....................................................................................................................................................... 31

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C h a p t e r 1

I n t r o d u c t i o n

1.1 OBJECTIVE

The main objective of the EPDItaly Programme and of these Regulations is to provide an instrument for developing, validating and publishing of Environmental Product Declarations, in which the Organisation can provide environmental information related to its products or services. The Program is valid for every Organisation working in any industry and country.

Organisation means:

- Environmental Product Declaration owner; - a manufacturer; - a group of manufacturers; - a Trade Association.

In fact, the EPDItaly Programme, just like these Regulations, are in accordance with ISO 14025 standards. In the Regulations there are supplementary indications about EPDs in compliance with EN 15804 and CEN/TR 16970.

Before the publication, the regulations must be subjected to public consultation, to cover at least one month (see. §3.6). It shall be reviewed every 3 years or to suit them to market needs.

In case of non-substantial amendments (for example: editorial or minor regulatory updates, etc ...) the period is 10 days. In case of substantial changes the comments is reviewed by of the Advisory Board.

The Environmental Product Declarations of products falling within the same product category though developed in different Programmes, may not be comparable.

According to the EPDItaly Programme, the information set out in the EPD must be obtained via LCA studies carried out Is in accordance with ISO 14040 standards, which are recognized worldwide.

1.2 DEFINITIONS AND REFERENCE

For the purpose of this document reference is made to definitions and content of the following standards:

ISO 14020, Environmental Labeling: General Principles;

ISO 14021, Environmental labels and declarations - Self-declared environmental claims (Type II environmental labelling);

ISO 14024, Environmental labels and declarations -- Type I environmental labelling -- Principles and procedures

ISO 14025, Environmental labels and declarations – Type III Environmental declarations – Principles and procedures;

ISO/DTS 14027, Environmental labels and declarations – Development of product category rules;

ISO 14040, Environmental management – Life cycle assessment – Principles and framework;

ISO 14044, Environmental management – Life cycle assessment – Requirements and guidelines;

ISO/TS 14071, Environmental management – Life cycle assessment – Critical review processes and reviewer competencies: Additional requirements and guidelines to ISO 14044:2006;

EN 15804, Sustainability of construction works. Environmental product declarations. Core rules for the product category of construction products;

CEN/TR 15941 Sustainability of construction works. Environmental product declarations. Methodology for selection and use of generic data;

EN 15942, Sustainability of construction works - Environmental product declarations - Communication format business-to-business;

EN 15978, Sustainability of construction works. Assessment of environmental performance of buildings. Calculation method;

EN 16485, Round and sawn timber – Environmental Product Declaration – Product Category Rules for wood and wood-based products for use in construction;

CEN/TR 16970, Sustainability of construction works — Guidance for the implementation of EN 15804;

ISO 19011, Guidelines for auditing management systems;

ISO 21930, Sustainability in buildings and civil engineering works — Core rules for environmental declaration of construction products and services used in any type of construction works;

Guidance for Product Category Rule Development, PCR Guidance Development Initiative.

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In addition shall be applied the following definitions:

Validation Action whereby a third party verifies the accuracy of the data in the EPD.

Certification Attestation of compliance with specified requirements.

Registration Action whereby EPDItaly identifies the EPD of the Organisation applying for publication.

Publication Action whereby EPDItaly publishes the EPD of the applying Organisation.

1.3 ABBREVIATIONS

For the convenience of the reader the key terms are as follows:

2 B2B 3 Business to Business

4 B2C 5 Business to Consumers

6 CPC 7 Central Product Classification

8 EPD 9 Environmental Product Declaration

10 LCA 11 Life Cycle Assessment

12 LCI 13 Life Cycle Inventory

14 LCIA 15 Life Cycle Impact Assessment

16 PEF 17 Product Environmental Footprint

18 PCR 19 Product Category Rule

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C h a p t e r 2

O r g a n i s a t i o n

2.1 STRUCTURE

ICMQ, Via G. De Castillia, 10 20124 Milan, is the EPDItaly Programme Operator. ICMQ is responsible for managing (also financial) the entire operative structure. In accordance with ISO 14025 standard (§ 6.3), the Operator has a number of obligations that are fulfilled via the following bodies:

Technical Secretariat

Advisory Board

General Committee

PCR Review Panel

PCR Committee

PCR Moderator

PCR Stakeholder Group

Certification Body

2.1.1 TECHNICAL SECRETARIAT

The Technical Secretariat:

Publishes the PCRs developed and approved by the PCR Review Panel, on website www.epditaly.it/pcr/. It monitors the maintenance.

Publishes the EPDs on website www.epditaly.it.

Manages on the website all the applicable documents (e.g. the pricing)

2.1.2 ADVISORY BOARD

The Advisory Board is the body that:

4.1 Analyses the market

It collects and analyses market feedback with a view to reviewing these Regulations.

It checks whether the PCRs should be changed.

It monitors market sensitivity to product sustainability.

4.1 Promotes the Regulations

It suggests activities/events to promote the EPDItaly Programme.

It gives inputs on the management of the Regulations.

It gives the Technical Secretariat indications on potential technical evolutions and developments of the

EPDItaly Programme.

The advisory board includes at least 8 members chosen from amongst the representatives of manufacturers, users and third parties.

2.1.3 GENERAL COMMITTEE

The committee includes at least 2 members and the President whose task is:

1. To ensure the application of the Regulations

It prepares, communicates, and submits the Regulations and PCRs of the EPDItaly Programme to review.

It is responsible for the conformity of the Regulations and PCRs to ISO 14025 and ISO 14040 and, for construction products, EN 15804 standards.

It approves a credible procedure for the open consultation of the Regulations during their

development/review.

It approves the check lists and specific tools defined in compliance with these Regulations.

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It approves the procedures designed to ensure the traceability and consistency of the database of

Organizations and their EPDs.

2. To approve the publication of a PCR

It appoints a PCR Moderator.

It guides the development of Product Category Rules (PCR).

It approves a credible procedure for the open consultation of PCRs during their development/review.

It makes sure that the application of the PCRs review procedure is carried out in a transparent and reliable

manner.

3. To approve the publication of an EPD

It makes sure that the application of the LCA and EPD validation procedure is carried out in a transparent

and reliable manner.

It decides on the publication of EPDs on the basis of reports produced by the verifiers.

It makes sure that the verifiers' activities are carried out in accordance with these Regulations.

2.1.4 PCR REVIEW PANEL

The PCR Review Panel must include at least an LCA expert (preferably with previous experience in the product category

in question) and an expert in the specific product category. The latter may be a representative of a manufacturing

company or of a commercial, technical or industry association. A chair will be elected by General Committee. The PCR

review panel chair is responsible for ensuring that all opinions are considered in a fair and equitable manner. The PCR

review panel members shall declare their independence and competencies prior to the review process.

The combined competence of PCR Review Panel should include:

- general background knowledge of the relevant sector, product and product-related environmental aspects;

- expertise in LCA and methodology for LCA work;

- awareness of relevant standards in the fields of environmental labeling and declarations and LCA;

- knowledge of the regulatory framework within the scope of the PCR;

- knowledge of the EPDItaly Regulament.

2.1.5 PCR MODERATOR

The PCR Moderator is mainly involved in the development and review of PCRs.

His tasks may be summarized as follows:

To identify the most appropriate product category, according to PCR Committee.

To prepare time schedules for the development of PCRs, submitting them to the PCR Review Panel.

To prepare the draft of PCRs and submit it to the PCR Review Panel that checks fulfillment of all

requirements, in accordance with these Regulations.

To assist the PCR Review Panel in the definition of the stakeholder groups to contact/involve in PCR

development, review and open consultation.

To manage the comments about public consultation process and critically examining them.

Where necessary, to review the PCRs on the basis of the comments and proposals for change received,

preparing a final draft of the document.

To inform all the parties involved in PCR development/review about the final document, prior to its

publication on the website.

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Once the PCR is operational, to collect the consultation group's feedback on any adjustments to include in the

future review.

To ensure an adequate consultation during the development/review of documents, encouraging the

participation of interested parties.

2.1.6 PCR COMMITTEE

The PCR must be drawn up by a Committee. The latter must include a sufficient number of members to ensure the interests of all parties so that none prevails over the others.

The PCR Committee should include:

at least 2 representatives of independent Organisations;

at least 1 LCA expert;

at least 1 interested party. The conditions to be met by the members are academic conditions:

for LCA experts: degree and at least 3 years of experience in LCA development;

for industry representatives: experience of at least 3 years or degree

2.1.7 PCR STAKEHOLDER GROUP

The PCR Stakeholder Group participates in the development/review of PCRs. The group should consist of persons who, at national and international level, are able to cover, by reason of their skills and knowledge, the various stages of the life cycle of the product category for which the PCRs are being developed/reviewed.

2.1.8 INDEPENDENT VERIFIERSP

The Certification Body:

make sure that the LCA study which is the source of the information used in the EPD, is in accordance with

the applicable requirements of standards, these Regulations and the applicable PCR;

ensures that the model adopted in the LCA product study is in line with actual facts;

verifies that the data in the EPD are represented in accordance with the provisions of these Regulations and

the applicable PCR;

produces a report specifying the elements of review of the documents analysed (Project Report and EPD),

including the settlement of any Non-conformity or Recommendation, and the position on the validation of

the EPD.

The EPD can be certified by resorting to Certification Bodies recognized by EPDItaly according to its own specific procedures, that refer to an accreditation issued by an Accreditation Body with International Mutual Recognition agreement (EA, IAF, …). It is the responsibility of each Certification Body to guarantee the expertise of the verifiers acting on its behalf and oversee their work.

For more details on the operational methods of a Certification Body, see Annex 2 to this document.

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C h a p t e r 3

P C R d e v e l o p m e n t

3.1 INTRODUCTION

To make sure that different EPDs relating to products within the same category can be compared, all the EPDs of that category must be built on ISO 14040-compliant LCAs developed within the same framework of prerequisites (see ISO 14025 6.7.2 and EN 15804 § 5.3, for construction products). To this end, an ad hoc set of rules must be developed since different product categories can be characterized by specific requirements; calculation methods must also be defined that must be necessarily applied when any EPD is developed. The rules that apply to all EPDs are represented:

a) by these Regulations; b) by the PCRs, Product Category Rules, for the different product categories.

In short, PCR development should follow the following scheme:

a. Express and motivate the need for PCRs b. Determine the product category c. Perform PCR search d. Announce intention to develop PCRs e. Involve appropriate stakeholders f. Create PCR committee g. Create PCR h. Create PCR review panel i. Moderator appointment j. Public consultation k. Comment and PCR review l. PCR publication

In accordance with ISO 14025 standard, 6.7.1, the PCRs must identify and document the purpose and scope of application of information based on the LCA for the product category and the rules for the production of additional environmental information for the product category. The PCRs must also establish the stages of the life cycle to be included, the parameters to treat and the conditions in which the parameters are to be collected and communicated in a report. For the sake of completeness and consistency, the PCRs must be based on one or more life cycle assessments (in accordance with ISO 14040 standards) and on other pertinent studies to identify the requirements for additional environmental information. Reference must be made to these life cycle assessment studies and to other pertinent studies in the PCR document. EPDs based on different PCRs that derive from different Program Operators may not be comparable.

3.2 PRELIMINARY VALIDATION

In order to facilitate the development of EPDs and thus to strengthen consumer/market sensitivity to the conscious purchase of products selected also on the basis of their environmental performance, an EPD can be developed without an PCR, under some conditions.

The EPDItaly Programme establishes that an EPD can be registered by following only the criteria of these Regulations, if there is no appropriate PCR document. This Preliminary Validation is valid for 18 months and is not renewable. Preliminary validation is the first step to develop a PCR since it can prompt a discussion between the various Stakeholders.

To obtain the Preliminary Validation via an independent verifier's validation, the format and minimum content of the EPD must be in accordance with the provisions of these Regulations (cfr. § 4), and the LCA study must be developed in accordance with ISO 14040 and 14044 standards, and EN 15804 for construction products. The Preliminary validation and its duration must be clearly indicated in the EPD.

3.3 EXPRESS AND MOTIVATE THE NEED FOR A PCR

The need to develop a PCR may result from an indication given by an Organisation or out of the need of EPDItaly.

3.4 PRODUCT CATEGORY DETERMINATION

The UN CPC international classification (http://unstats.un.org), in its updated version, allows for the definition of the scope of application of the PCR.

Where there is no clear CPC for the product in question or the product covers several CPC codes, the PCR Review Panel, if necessary, will provide guidelines on PCR development.

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According to ISO/DTS 14027 standards, the PCR will be split into:

a. Core-PCR, if it contains a set of compulsory parameters to be declared for a group of product categories; b. sub-category PCR, containing additional requirements.

3.5 CHECKING THE EXISTENCE OF PCRS

After verifying that there are no PCRs available in the EPDItaly Programme for the product covered by the initiative, the existence thereof within other Programmes managed by different Operators should be checked.

The following results may ensue from such search:

There is no PCR

In this case, a PCR must be developed.

There is a PCR

In order to prompt harmonisation, the adoption of PCRs readily available in the same product category and in the appropriate market area may be taken into account. The PCR Review Committee checks conformity to these Regulations and adopts the PCR:

a) without bringing any change, checking its conformity to these Regulations and to applicable Standards;

b) supplementing its content with additional requirements so as to ensure the representativeness of the document.

The Program Operator with whom the PCR of its adoption is recorded, should be notified of such changes.

However, there may be valid reasons to develop PCRs differing from existing ones. The efforts made to achieve harmonisation, and the outcome and reasons for non-adoption of readily available PCRs, should be specified in the document. This may be the case where, for instance, the PCR is more than three years old or is based on local information that is not applicable in other Countries.

EN 15804-compliant PCRs, published as European standards (EN Standards) for a product category, must prevail over any other available PCR, except as otherwise justified for technical reasons. For this reason, EPDItaly might adopt the European standard, in special conditions, without any change and public consultation. In this case, the transition period is 6 months from the date when the standard is made available.

3.6 ANNOUNCE INTENTION TO DEVELOP PCRS

EPDItaly will inform the interested parties of the publication, on the website www.epditaly.it, of the launch of the initiative to develop the PCR. Both the information sent to potential Stakeholders and the website announcement will be completed by a basic schedule of activities. This schedule will include the PCR scope, the Proposal Organisation, the information about EPDItaly and the expected timing of the development stages. Everyone can submit a PCR development request.

The open consultation phase must last at least one month. Similarly, except as otherwise required by special developments, the moderator should answer any comments received and thus adjust the PCR in 1 month.

3.7 STAKEHOLDER INVOLVEMENT

To ensure that the PCR is a document shared by the various operators acting in the same product category, the calculation rules and the assumptions included in the PCR should be the result of teamwork. Therefore, several operators potentially interested in the product under study should be involved and collaborate in this respect. The operators should be chosen at international level, as far as possible.

In addition to the small group of operators who may be actively involved in drafting the PCR, it is important to identify also the potential Stakeholders-product experts who will be part of the Consultation Group of the forum and who, being experts in the field, will provide useful indications during the drafting of the PCR final version.

3.8 CREATION OF THE PCR COMMITTEE

The General Committee establishes the PCR Committee to PCR development.

EPDItaly can ensure the PCRs consistency, because the PCR Committe tasks are defined as follows:

1. Product Category choice; 2. PCR development (see § 3.9) according to EPDItaly Regulament; 3. PCR amending (see § 3.5), where appropriate; 4. Moderator appointment; 5. Comments reviewing and approving, at the end of the public consultation stage; 6. PCR sending to PCR Review Panel; 7. PCR Review Panel comments review; 8. PCR sending to EPDItaly to open public consultation.

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No single Organisation should dominate the PCR Committee, either economically or in manufacturing terms. EPDItaly will take steps to avoid any conflict of interest.

The appointment of the PCR Committee will be formalised by EPDItaly to favour and promote its widespread participation.

3.9 PREPARING THE DRAFT DOCUMENT

The PCR is used to define, in relation to the product category in question, which rules should be followed to define the system boundaries or which quality requirements should be considered during data collection, in the LCA study used to prepare the EPD; it also establishes which declared unit, also known as functional unit, should be referred to and which information should be included in the EPD.

Specifically, the PCR should consider:

CPC code and description of the product category it refers to.

Identification and validity of the document.

Functional and/or declared unit.

System boundaries.

Objective and scope of application of LCA-based information.

Description of data.

Data cut-off criteria.

In case of application of EN 15804, other criteria for the data exclusion could be applied (see. §6.3.5 of EN 15804).

Data quality requirements, including coverage, precision, completeness, representativeness, consistency, reproducibility, sources and uncertainty.

In case of application of EN 15804, the additional requirements shall be applied (see §6.3.7 of EM 15804).

Inventory analysis.

Allocation methods, including data collection.

The database to use where the LCA result can be significantly influenced by its choice.

List of mandatory impact categories, calculation methods and corresponding indicators.

Predetermined parameters for the communication in a possible report of LCA data.

Information on the minimum content of EPD.

Materials and substances that may be harmful to health and that should be declared.

Indications to promote comparability.

Requirements for additional environmental information.

Indication of the stages of the life cycle that are not considered and omitted by the EPD.

Information to be included in the final stage of the life cycle, the useful life included.

Additional information, e.g. information on the use of management systems or certifications relating to the product, waste management, etc.

Reference to the documents used for PCR development, such as LCA studies or other relevant studies, applicable rules, etc.

Requirements for the supply of additional environmental information, including all methodological requirements.

Instructions for the production of data required to develop the declaration (LCA, LCI, information forms and additional environmental information).

Instructions on EPD content and format.

Period of validity of information.

Data on product environmental performances.

Any additional environmental information included in the PCR must be comparable (see ISO/DTS 14027 standards).

3.10 CREATION OF THE PCR REVIEW PANEL

Once the PCR has been developed, or at the same time thereof, a PCR Review Committee must be established. The characteristics and responsibilities of its members are defined in chapter 2. The task of PCR review panel are: a) PCR review in accordance with EPDItaly Regulament ad applicable Standards; b) to verify that the methods required by the PCR are scientifically and technically valid; c) to verify that the required data are appropriate and reasonable in relation to the PCR; d) send the comments to PCR Committee, with a standard format.

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3.11 MODERATOR APPOINTMENT

The moderator is required to provide the support necessary for a harmonious development of PCRs. The moderator must necessarily be familiar with the development of LCAs and EPDs.

The moderator is identified together with EPDItaly.

The duties of the moderator are indicated in § 2.1.5.

3.12 PUBLIC CONSULTATION

The consultation phase is designed to ensure that the main operators involved, in different capacities, in the life cycle of the product category, are informed of publication of the PCR so that they can submit their comments and proposals for change before the PCR document is formalized in its final version.

The document is thus published on the website www.epditaly.it as a PCR for open consultation. The PCR Review Panel indicates a moderator for each PCR whose task is to collect comments, lead the discussion, provide any clarification and answer, and evaluate proposals for change, checking their compliance with these Regulations.

The consultation forum involves:

the PCR Stakeholder group (see §2.1)

the moderator

any Stakeholder in the production chain, LCA/EPD experts, consumer associations, verifiers recognized by EPDItaly and anyone who asks to participate in the forum by subscribing thereto.

The forum is managed online on EPDItaly website (www.epditaly.it). Flexibility of access ensures the widest possible participation.

The consultation phase is opened by EPDItaly via an announcement on the dedicated website www.epditaly.it. The public consultation phase lasts one month, unless necessary changes to the timing decided by EDItaly . The comments received are examined by the moderator who then brings any changes to the first draft of the PCR, drawing up a summary of such changes.

EPDItaly through the website:

- shows that a balance of all interested parties was invited, - justifies why any interested parties are excluded, - provides an explanation when one or more parties choose not to participate.

3.13 MANAGEMENT OF COMMENTS AND REVIEW OF PCR

The comments received are examined by the moderator who provides for their possible incorporation, making all adjustments to the PCR.

The moderator keeps a list of comments and changes introduced over time. Once a consolidated version of the PCR is obtained, the moderator submits it to the PCR Review Panel for its final approval.

The comment management procedure is in accordance with the Guidance for Product Category Rule Program Developers, 4.2 ff., and ISO/DTS 14027 standards, 7.

The PCR review is designed to confirm its validity.

Specifically, the review should ensure:

a. the conformity of the PCR to ISO 14025 and ISO/DTS 14027 standards; b. that the methods required by the PCR are scientifically and technically valid; c. that the data required are appropriate.

Following the review, a report is issued that is given to the PCR Committee for any appropriate changes/additions. The report may be consulted by submitting a reasoned request therefor.

The review report shall contain at least the aspects mentioned in ISO/DTS 14027 § 7.4.

3.14 PCR PUBLICATION

In this respect, the PCR Review Panel is required:

to verify that the PCR drafting process and the management of the consultation forum took place in accordance with these Regulations;

to make sure that the PCR is consistent with these Regulations;

to check that the comments made in the forum during the consultation phase were duly examined.

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The Committee may make comments which the moderator is required to take into account so as to go ahead with PCR approval. The moderator may thus re-open the forum to issue a new PCR draft. Once the Committee's evaluation is positive, the PCR is published on the website and is assigned a registration number.

The PCR will be published with the following information:

1. Registration number 2. Scope 3. Product Category 4. Products covered by PCR 5. Information about the use 6. the life cycle stages considered 7. keywords relating to the PCR; 8. geographical coverage of the PCR 9. date of publication and expiration 10. applicable Standards 11. history of PCR; 12. name and contact details of EPDItaly 13. PCR committee contact details; 14. list of involved interested parties 15. PCR review panel contact details 16. where the PCR review can be obtained.

3.15 UPDATE

The validity of the PCR is indicated in the document itself, though it cannot exceed 5 years. Three months before the deadline, the moderator will open a new consultation phase to update the document.

If the updating phase goes beyond the expiry of the PCR, the EPDs cannot be validated with respect to the expired PCR version. The EPDs that are registered and validated according to the expired PCR shall remain valid for until their natural expiry. After said expiry, the Organisation may decide whether to remove or leave them in the EPDItaly database. In fact, EPDItaly allows the Organisation to use the EPD document for products still in stock, though subject to its written authorisation.

It might be necessary to review the PCR before its expiry where required, for example, by market needs. Comments on the PCR can be sent to EPDItaly during the period of its validity and thus lead to PCR review, before its expiry.

Conversely, if no significant comment is received during the period of validity of the PCR, the Technical Secretariat itself will extend the validity of the PCR.

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C h a p t e r 4

T h e E P D D e c l a r a t i o n

4.1 EPD TYPE

The following types of EPD are recognised, in accordance with applicable standards, whose classification may be deemed valid for all products and not only for construction products:

1) Product EPD a) declaration concerning a specific product by a specific manufacturer; b) declaration concerning the average manufacturing of a product at different plants, by a specific manufacturer; c) declaration concerning the average product among different products at a specific plant, by a specific

manufacturer; d) declaration concerning the average product among different products at different plants, by a specific

manufacturer; 2) Sector EPD

a) declaration concerning the manufacturing of a specific product, as the average value of manufacturing at different plants, by different manufacturers;

b) declaration concerning the manufacturing of an average product, as the average value of manufacturing of different products at different plants, by different manufacturers;

3) Product EPD based on qualified calculation algorithm (see Annex 3 and Annex 4). The above list is not an exhaustive list.

4.2 BASIC REQUIREMENTS OF THE DECLARATION

To make sure that EPD formats are uniform, even where these cover different product categories, the EPDItaly Programme provides for some common rules:

information on the Program Operator;

product description and content of materials;

environmental performance of the product and additional information;

any other required information.

EPDs must be in compliance with the ISO 14020 requirements and can be written in Italian or English.

The EPD is valid for five years, after which the declaration must necessarily be issued again.

In case of construction products the validity is determined by EN 15804 and, to favour harmonisation of the content within the document, reference should be made to Annex 1 of these Regulations.

4.3 INFORMATION ABOUT EPDITALY

The EPD must include:

the reference to EPDItaly, and to www.epditaly.it website;

the EPDItaly logo;

EPDItaly reference number;

The possible ECO Platform logo with reference number;

a reference to the PCR(name, product category, registration number);

the date of EPD publication, update (if applicable) and its validity (five years from first issue);

4.4 PRODUCT DESCRIPTION AND CONTENT OF MATERIALS

The EPD must include:

the trade name of the product and its identification (for example, its model or code);

the CPC code;

a brief description of the Organisation, including the address, the logo and reference to any management system certification. Comparative judgements concerning other Organisation or their products are not allowed;

Production plant address;

technical description of the product, together with a visual representation thereof, its possible uses, useful life, functional characteristics, manufacturing process, main components, possible packaging and CE marking, geographical area of EPD application;

functional/declared unit, consistently with the corresponding PCR;

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any hypotheses or assumptions;

content of the main materials: o list of materials and chemical substances, specifying any hazardous substances or the release thereof into

water, air, ground. For the classification of substances, reference must be made to the following international classifications: Regulation (EC) No 1907/2006 (REACH) and Regulation (EC) No 1272/2008;

o in the case of substances or materials covered by a patent or by industrial secrecy, the information to be provided will be limited to the declarations given by their manufacturer in brochures, commercial-technical sheets or safety data sheets.

Additional environmental information;

information on the content of recycled materials, recovered materials or byproducts, indicating the specific regulatory and/or legislative reference used to qualify the indicated material. To avoid any misunderstanding, in compliance to ISO 14021:

o recycled materials include pre- and post-consumer waste; o material recovered internally and used in the same process that generated it cannot be considered as

recycled material.

Statement that the EPDs from different programmes may not be comparable.

Information on the places where explanatory materials are available.

If an EPD refers to an average Product or Sector EPD, the following details must be given:

the representativeness of the sample and how it was chosen;

description of how the sites and products were chosen;

information on the most significant environmental performances;

the name of the Organisations included in the EPD;

information on restrictions to the use of the EPD;

technical description of the average product;

number of manufacturing plants included in the EPD;

description of production volume covered by the EPD;

geographical coverage;

range of products for which the EPD is relevant.

Selecting the products considered when defining the average EPD must be done in such a way that the impacts of the resulting average EPD are reasonably representative of the impacts of the products themselves. This assumption must be justified in the document.

One useful reference is ISO 21930, in which products included in the EPD do not differ in their environmental impacts by ±10%. If the impacts differ by more than ±10%, the product impact categories may be listed in the EPD itself, though in separate tables.

The unit of measurement of the data must be reported to the S.I. For Construction products EPDs the §6.3.9 of the EN 15804 and §7 of the CEN/TR 16970 standard must be applied.

4.5 ENVIRONMENTAL PERFORMANCE OF THE PRODUCT AND ADDITIONAL INFORMATION

The information relating to the environmental performance of the product that must be reported in the EPD will cover data such as the consumption of natural resources, both with and without energy content as well as potential environmental impacts.

The following data must be declared:

data of the LCA (including the stages that are not considered), the inventory and information forms;

the LCA reference version and any software used;

the type of EPD (product, sector EPD etc.)

the reference year and the source and quality of data used in the LCA study;

The database used.

The general criteria and the way in which such information is arranged, are specified for construction products in Annex 1 of these Regulations. Further, specific details may be required by the corresponding PCRs.

4.5.1 LIFE CYCLE STAGES

The LCA study from which the data included in the EPD will be drawn, must be written in such a way that the environmental performances of the product are specified for each life cycle stage. These Regulations provide that life cycle stages must refer to segmentation in the three following modules:

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Upstream module, which includes all the relevant processes of the supply chain, such as: o the extraction of raw materials including waste recycling and the production of semi-finished products

and auxiliary items, as well as the packaging of products and semi-finished products; o the transport of raw materials to the manufacturing company.

Core module, which includes all the relevant processes managed by the Organisation that proposes the EPD, such as:

o the impact of the production of the electricity consumed according to the relevant energy mix, the production, installation and disassembly of infrastructures where these have a significant effect on the life cycle (for example, for the rail transport service), the impact of the combustion of fuels on the production site, the impact of water and/or air pollutant emissions;

o the impact of the construction/dismantling of production facilities, or of the production site, when these have a significant effect (for example for wind power plants or for oil drilling platforms).

Downstream module, which includes all the relevant processes that take place beyond the gate of the site of the Organisation that proposes the EPD:

o product transport o product installation o use o maintenance o waste transport o waste treatment process o disposal

Upstream and Core stages represent the boundaries of cradle to gate EPDs, while the three stages taken as a whole represent the boundaries of cradle to grave EPDs.

The standard EN 15804 provides a different phases of the life cycle (see. §6):

A. PRODUCT STAGE

Module A1: Raw material supply

Module A2: Transport

Module A3: Manufacturing

B. CONSTRUCTION STAGE

Module A4: Transport

Module A5: Installation

C. USE STAGE

Module B1: Use

Module B2: Manteinance

Module B3: Repair

Module B4: Replacement

Module B5: Refurbishment

Module B6: Operational energy use

Module B7: Operational water use

D. END OF LIFE STAGE

Module C1: Demolition

Module C2: Transport

Module C3: Waste processing

Module C4: Disposal

E. BENEFITS AND LOADS BEYOND THE SYSTEM BOUNDARY

Module D: Reuse-recovery-recycling potential.

Therefore, for construction products, instead of upstream, core and downstream modules A1-A3, A4-A5, B1-B5, B6-B7, C1-C4 and D will be used, considering the boundaries from cradle to gate, from cradle to gate with options, from cradle to grave, as required by standard EN 15804.

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For each module taken into account, the related processes and all necessary additional environmental information must be described clearly. For construction products modules A1-A3 are mandatory, for every system boundary.

The modules that are not declared will be marked as “MND” (Module Not Declared).

The indicators may report the assessed value or:

INA (Indicator Not Assessed);

“0” if the value is zero;

The “polluter pays” principle must be applied, referring to what is defined in the CEN/TR 16970 standard.

4.5.2 ENVIRONMENTAL PERFORMANCES WHOSE DECLARATION IS REQUIRED

The impact categories need to the specified for each module of the product life cycle pertaining to the EPD, as defined by the relevant PCR, on the basis of which the EPD has been developed.

The EPD, in any case, must include the following categories. Such information must be clearly separated into the following three categories:

o analysis of data of the LCI, according to the PCR, for inclusion of: - consumption of resources, including energy, water and renewable resources, - emissions to air, water and soil;

o results of the LCIA, when applied, with the inclusion of: - global warming, - ozone depletion, - acidification for soil and water, - eutrophication, - photochemical ozone creation, - depletion of abiotic resources elements, - depletion of mineral resources;

o other data such as the amount and types of waste produced (hazardous and non-hazardous waste).

The declaration must indicate if the assertion is related to the complete product or not, packaging or service or service element, to a building or infrastructure or part of them.

In case of construction products, the mandatory environmental performance, are described in Table from 3 to 12 of EN 15804.

The characterisation factors to be used are those in their current version published by CML (Instititute of Environmental Sciences, Leiden University). If EN 15804 is used, Annex C thereof applies.

Within the possible mutual recognition (for example ULE) the use of TRACI (Tool for the Reduction and Assessment of Chemical and Other Environmental Impacts; United States Environmental Protection Agency) characterization factors could be mandatory in the current version established by the United States Environmental Protection Agency and the impact categories that refer to different characterisation factors must be reported separately in the EPD document, specifying the characterisation factors which they refer to.

Where necessary, each PCR will specify which optional indicators must be included in the EPD. These indicators must be specified in the EPD as “additional”, but not necessarily in an annex. In addition, the PCRs may indicate further impact categories that should be taken into account, for example in the light of the Product Environmental Footprint (PEF) developed by the European Union or of specific standards for the development of PCRs such as ISO 15804, specifying the applicable characterising factors for each impact category.

4.5.3 ADDITIONAL ENVIRONMENTAL INFORMATION

If it is deemed useful, the EPD can include environmental information that is not directly obtained from the calculations of the LCA study but that may be significant nonetheless, especially for the environmental impacts during product use, maintenance, and end of life.

For instance:

information on proper product disposal during end of life (e.g. separation of product parts for their proper allocation);

information concerning proper use and maintenance, for example to contain energy consumption or reduce the consumption of cleaning products, noise emissions, or air pollutant emissions;

information on the life of product parts so as to reduce replacements and thus the consumption of raw materials;

information for product reuse;

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data on product performances, where they are significant in environmental terms (e.g. fire resistance or mechanical strength or CR marking);

information on environmental issues, such as: - impact(s) and potential impact(s) on biodiversity,

geographical aspects related to the stages of the product life cycle, for example its conditions of use;

adherence of the Organisation to any environmental management systems, specifying the places where interested parties can find details on such systems;

any other environmental certification scheme applied to the product and a declaration of the places where interested parties can find details on the certification system;

hazard and risk assessment on human health and the environment;

information on absence or level of presence of a material in the product that is considered of environmental significance in certain areas;

other environmental activities of the Organisation, such as the participation in recycling or waste recovery programmes, as long as details on these programmes are made available to the buyer or user.

potential events, e.g. accidents, which might have an impact on the environment;

information on how environmental issues are addressed as a whole by the Organisation that wants the EPD validation. For example, the adoption of environmental management systems, social responsibility activities, the participation in foundations for the protection of the environment/arts/architecture, etc.

Such information must be in accordance with ISO 14025 standards and must be kept separate from the information referred to in the previous paragraphs.

In case of construction products, the additional environmental performance are described in Tables 6-7-8-9-10-11 and 12 of EN 15804.

4.5.4 OTHER REQUIRED INFORMATION The EPD must include:

The reviewer of the reference PCR;

Data obtained from the LCA, LCI (see §5.3.2 ) or information forms, as specified in ISO 14025 standards.

Content declaration of materials and substances to declare (for example, information on the content of products, including specifications of materials and substances that may be harmful to health and/or the environment, across all the life cycle stages) listed in the “Candidate List of Substances of Very High Concern for authorisation” when their content exceeds the limits for registration with the European Chemicals Agency.

System boundary (cradle to gate or cradle to grave).

Type of EPD (product EPD, sector EPD, …).

A diagram showing the various stages of the life cycle falling within the boundaries of the analysed system, with explanations on any omitted stages.

Information on the places where explanatory materials are available.

Allocation rules and cut-off criteria.

The sentence "EPDs relating to the same category of products but belonging to different programmes may not be comparable".

The sentence "EPDs relating to construction products may not be comparable if not compliance with EN 15804".

In the case where an EPD is declared as an average environmental performance for a number of products, a statement to that effect shall be included in the declaration together with a description of the range/variability of the LCIA results if significant.

EPDItaly logo.

The following table:

Standard EN 15804 serves as the core PCR (if applicable)

Independent verification of the EPD and of its data, in accordance with ISO 14025 standards, by

Verifier

Internal External

Third Part Verification Certification Body name (with refer to Accreditation Body and accreditation number)

Table 1 - mandatory diagram

The communication format, for EPD in compliance with EN 15804, must be in compliance with EN 15942.

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An example of a format containing all necessary information is given in Annex 1 (in English).

4.6 SECTOR EPDS

Since the environmental sustainability of products has become a key topic within several trade associations, EPDItaly provides for the possibility of communicating product environmental performances by using information on production processes of several operators within the same sector. The environmental performances that are representative of an average product/service can thus be communicated through the direct involvement of an adequate number of sample processes. The sector EPD is nothing but a Type III Environmental Declaration referring to data of a large number of production sites in a well-defined geographical area. As regards the format and content of the EPD, please refer to the paragraphs above..4

4.7 EPD BASED ON QUALIFIED CALCULATION ALGORITHM

In the event that an Organization use the same algorithm to develop different LCA, for the purpose of publication of different EPD, it is possible to optimize the EPD verification with an algorithm qualification process and the correct use of the algorithm verify.

In fact, the algorithm, based on the same LCA model, allows to determine the different impacts of products, in case of input data changing. The EPD verify is simplified because it is not necessary LCA checking every time (see cap. 5 and Annex 3 and Annex 4).

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C h a p t e r 5

E P D D e v e l o p m e n t a n d V e r i f i c a t i o n

5.1 DESCRIPTION OF THE PROCESS

The process of EPD development generally follows the scheme below: 1. Checking the existence of PCRs (see §3) 2. Possible development of a new PCR (see §3) 3. LCA Study (see §5) 4. Report LCA and EPD (see §5) 5. LCA and EPD verify and validation (see §5) 6. Registration and Publication (see §6)

The independent verification of data from LCA, LCI and information forms, as well as of additional environmental information, shall be performed by an Accredited Certification Body (2.1.8) and must confirm:

conformity to the PCR;

conformity to ISO 14040 standards;

conformity to the general instructions of the programme for Type III environmental declarations;

that data assessment includes coverage, accuracy, completeness, representativeness, consistency, reproducibility, sources and uncertainty;

plausibility, quality and accuracy of data based on the LCA;

quality and accuracy of additional environmental information;

quality and accuracy of support information.

The independent verification of the Environmental Product Declaration must be such as to establish whether the Type III environmental declaration is in accordance with:

ISO 14020 standards and the pertinent requirements of ISO 14025 standards;

the general instructions given by EPDItaly;

the reference PCR.

The EPD verification activity is structured into a documentary verification and EPD verification.

The activities for the preliminary verification and renewal of an EPD are usually carried out “on site” at the manufacturer’s facility and/or at the site of collection, management and processing of data for EPD development.

In case of EPDs generated by a qualified TOOL, see Annex 3 and 4.

Upon completion of EPD verification and validation activities, the Certification Body must issue a validation certificate (see Annex 2 – Section II), which will be sent to EPDItaly by the entity applying for the publication of the EPD being verified, which certifies the successful outcome of the binding independent verification for the publication of the EPD in the EPDItaly Program.

5.2 PRODUCT EPD VERIFICATION

5.2.1 AUDIT PREPARATION

The Certification Body must start the validation process by giving the details of the auditors entrusted with the verifications, after establishing their skills and independence (see §5.11 and Annex 2).

5.2.2 REGULATORY COMPLIANCE

The Organisation must ensure that the product for which the EPD is developed is in accordance with environmental regulations. If the Organisation is not ISO 14001 certified or EMAS registered, it may:

a) provide evidence every year of a self-audit in relation to compliance with environmental regulations and its positive outcome signed by its Legal Representative, for each manufacturing plant;

or, in addition:

b) undergo a voluntary Inspection by Certification Body on its regulatory compliance.

Or else, the EPD must include a statement that releases EPDItaly from liability for any non-compliance with environmental regulations self-declared by the manufacturer.

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EPDItaly gives value to Organisations that voluntarily choose to undergo such regulatory compliance Inspection.

In fact, the EPD must include, among additional information related to environmental issues, a specific statement specifying that the Organisation has undergone an independent third party Inspection relating to the environmental regulation control system.

If the Organisation is ISO 14001 certified or EMAS registered, this information must be reported in the EPD as additional information.

5.2.3 DATA VALIDATION

The validation stage is designed to make sure that the data used in the LCA study leading to the EPD, are accurate and that the model adopted in the LCA represents actual facts. For this reason, the validation stage is necessarily carried out via an on-site audit, at least for the first registration of the EPD and its renewal.

In fact, during the audit, there must be at least one product EPD drawn up by the Organisation. The verification is conducted by EPDItaly relying on auditors who have given proof of their independence and skills, in accordance with point 5.11 and Annex 2.

The activity implies a third party independent verification of all the Organisation’s EPDs, on the basis of a sample, in accordance with point 5.1.

5.3 SECTOR EPD AUDIT

5.3.1 AUDIT PREPARATION

See 5.2.1.

5.3.2 REGULATORY COMPLIANCE

The Organisations (Association or Consortium or Sector) must ensure that the product for which the EPD is developed is in accordance with environmental regulations. If the Organisations, that collect data, are not ISO 14001 certified or EMAS registered, they may:

a) provide evidence every year of a self-audit in relation to compliance with environmental regulations and its positive outcome signed by its Legal Representative, for each manufacturing plant;

or, in addition:

b) undergo a voluntary Inspection by the Certification Body on its regulatory compliance.

In case of companies or plants that are not covered by a UNI EN ISO 14001 accredited certification, the EPD must include a statement that releases EPDItaly from liability for any non-compliance with environmental regulations self-declared by the manufacturer

EPDItaly gives value to Organisations that voluntarily choose to undergo such regulatory compliance Inspection.

In fact, the EPD must include, among additional information related to environmental issues, a specific statement specifying that the Organisation has undergone an independent third-party Inspection relating to the environmental regulation control system. If one or more Organisations are ISO 14001 certified or EMAS registered, this information must be reported in the EPD as additional information.

5.3.3 DATA VALIDATION

See 5.2.3.

The auditor shall verify the following items:

the representativeness of the sample and how it was chosen;

description of how the sites and products were chosen;

information on the most significant environmental performances;

the name of the Organisations included in the EPD;

information on restrictions to the use of the EPD;

technical description of the average product;

number of manufacturing plants included in the EPD;

description of production volume covered by the EPD;

geographical coverage;

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5.4 EPD BASED ON VALIDATED CALCULATION ALGORITHM VERIFICATION

See Annex 3 and Annex 4.

5.5 DATA CONFIDENTIALITY

All data and news related to the Organisation, of which the Certification Body will be aware in the performance of activities under this Regulation, shall be confidential. Access to them must be regulated by a procedure, which provides for the duty of confidentiality to the Auditor and to all personnel involved in the processes covered by this Regulation.

As for the Organisation, this must give the verifier access to its data to ensure that the audit can be conducted properly by an independent party.

EPDItaly will communicate to the interested parties all information, in cases where the law requires them.

5.6 AUDIT REPORT AND MINUTES

The Auditors draws up a report in which evidence is given of the controls performed. The report must give evidence of any discrepancies and of any requests for clarification put forward by the verifier. For construction products, the auditor must fill in a specific check list, available on website www.epditaly.it. The report, where the Certification Body shall provide evidence of the checks, will have to allow the validation of EPD, without any non-conformities evidence. The Certification Body shall define the non-conformities level and manage them, according to its own procedures. Annex 2 contains the points that will cause the certification activities to be blocked. In the absence of any impediments, the Body must validate the EPD. For this purpose, the Certification Body shall have a deliberative body, that shall be composed by a chairman and at least two members. The combined competence is in the Annex 2. Annex 2 also defines the requirements for the first validation, maintenance, reduction/extension, renewal, suspension and revocation of the EPD.

5.7 VALIDATION MAINTENANCE

5.7.1 PRODUCT EPD

An EPD remains valid, after the verification, for a period of five years, beyond which it must be reviewed and verified, in accordance with the previous paragraphs. An EPD must be reviewed and updated when it is necessary to adapt its content to any technological changes or other circumstances that might alter its content and accuracy.

Every year the Organization has to declare, assuming responsibility therefor, if there are relevant modifications regarding the product environmental impacts or services/processes.

Any variation exceeding ±10% in the environmental performance of a product must be reported to the Certification Body. Such changes may require the EPD to be updated and thus call for a new verification thereof according to the procedure set out in the previous paragraphs.

In the case in which an updated LCA study identifies lower environmental performance values with respect to those found in the EPD, and the Organisation intends to modify the EPD, a supplemental verification will be necessary, in compliance with that indicated in 5.2.

If the EPD is not changed, it will remain published until its natural expiry, without any further verifications by the Certification Body.

The Certification Body must also establish, in its procedures, the option of conducting a verification whenever there arise doubts as to the manufacturer’s declaration.

5.7.2 SECTOR EPDS

See 5.7.1.

5.7.3 EPD BASED ON QUALIFIED CALCULATION ALGORITHM

Each EPD based on a qualified calculation algorithm remains valid, after the verification, for a period of five years, beyond which it must be reviewed and verified, in accordance with the previous paragraphs.

For each EPD, Annex 3 or Annex 4 is applicable.

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5.8 THE AUDITORS

The parties that can conduct third party verifications in accordance with these Regulations are the Certification Bodies recognized by EPDItaly, according to its own specific procedures, and accredited by an Accreditation Body that has signed international Mutual Recognition agreements (ES, IAF, …).

5.8.1 CHECKING THE INDEPENDENCE OF VERIFIERS

EPDItaly needs that the Certification Body, recognized by EPDItaly, control the auditor independence, by making sure these are not involved in LCA execution or in EPD development and have no economic relations with the Organisation.

The auditor must:

• be unrelated to any event or condition that can obstruct the free and peaceful performance of audit; • not have had economic relationships with the Organisation over the past three years • must commit not to take any relationships for all the audit duration; • be free from any conflict of interest that may affect the proper operation of audits;

• not be involved in LCA execution or in EPD development.

• not have any conflict of interest.

Accreditation or, in the case of construction products, the presence in Eco Platform as an Established Program Operator, as a pre-requisite to operate within the EPDItaly Programme, is a condition sufficient to EPDItaly to check such independence.

The auditor must warn EPDItaly in any cases of conflict of interest.

Lastly, EPDItaly analyses the risk connected with using the verifier.

5.8.2 CHECKING THE SKILLS OF VERIFIERS

The auditor competence is specified on ISO/IEC 17065 “Conformity assessment – requirements for bodies certifying products, processes and services” and ISO 19011 “Guidelines for auditing management systems”. The supervision of the verifiers' skills is based on:

the documentary verification of the verifiers' skills through the examination of their CVs, certificates, publications, etc.;

verifications carried out together with the Auditor by LCA experts.

The minimum skills required for verifiers are set out in EPDItaly procedures. It concerns:

o knowledge of relevant standards in the fields of LCA and EPD, ISO 14040-14044, ISO 14020, ISO 14024, ISO 14025, EN 15804, ISO 21930, ISO/TS 14071, CEN/TR 16970;

o knowledge of the relevant regulatory framework about the EPD product/service; o knowledge of relevant sector, product and service/product-related environmental aspects; o knowledge of process and service/product knowledge of the product category; o LCA and EPD audit knowledge; o knowledge of the Regulations and all the rules necessary for the proper performance of the activities, included the

ACCREDIA rules.

The proficiencies required for Certification Bodies are assessed by the Accreditation Body.

Accreditation or, in the case of construction products, the presence in Eco Platform as an Established Program Operator as a pre-requisite to operate within the EPDItaly Programme, is a condition sufficient to EPDItaly to check such qualifications.

In any event a continuous updating of competence must be demonstrated.

5.9 GENERAL RULES FOR LCA STUDIES

The LCA study must be structured in such a way that it meets PCR requirements. (In case of EN 15804, the study must be

structured as a Project Report, in accordance with §8 of the standards).

It must include any calculation tables, explanations and interpretations concerning the calculation models adopted by the Organisation and the assumptions made. In particular, data must be reliable and presented, in a Report, in a clear and transparent manner, for the different stages of the product life cycle.

General, specific data sources or literature data sources must be indicated in a clear and transparent way. To facilitate the verification, the LCA study must give indications on the time/geographical scope of data.

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The LCA must ultimately follow ISO 14040 standards, reporting: the objectives of the study and its scope of application, the system boundaries, indicating the stage of the life cycle - the declared/functional unit of the study, the inventory analysis (in a Table), the analysis of potential impacts and a sensitivity analysis.

As a general rule the LCA study, which is used to obtain the environmental indicators to include in the EPD, must be developed in accordance with ISO 14040 and ISO 14044 standards.

The LCA study must also be consistent with these Regulations and with what is set out in the PCR and in the EN 15804, if applicable, reporting the environmental indicators relating to the applicable impact categories. In particular, it must be consistent with the segmentation into the various stages of the life cycle of the product pertaining to the EPD and the product, as required by § 4.4.1 .

For every LCA stage the Organisation must be report a process description and a summary of the mandatory parameters.

The LCA study must indicate:

the boundaries of the study, in accordance with the applicable PCR, relating to the geographical area, time span, life cycle stages;

the declared/functional unit, according to the applicable PCR;

the technical specifications of the product regarding, for example: o its useful life, expressed as years, hours of use, km covered, etc. o its operating conditions used in the simulation o its maintenance conditions

definition of the cut-off criteria which allow for the omission of some data from the inventory when these are irrelevant for the purposes of the study and would only burden data collection without significantly changing the final result

description of data quality: o data relating to the environmental aspects of the system in question and consisting primarily of input and

output materials and energy with respect to the production system. These data pertain to the Organisation;

o data related to the impacts of product/material life cycles and of the energy flows used in the production process, resulting in general from a database. Input and output data related product LCA is classified into three types:

specific or primary data, collected directly from those who produce the product or supply the service or from the suppliers who, for example, can indicate the actual data on consumption or the emissions connected with the production cycle of the supply. These data must not be more than 5 years old and must refer to a full year of operation. The use of data representative of shorter operating periods must be adequately justified.

the category of selected generic or secondary data includes data from (paid or free) databases which are considered to be reliable to replace primary data, when not available. The databases that might be used in lieu of specific data must be included in the applicable PCR.

The database used should be the most up to date possible, and must not be more than 10 years old (5 for specific data).

generic data, i.e. data from other sources. As a general rule, the use of such data should be limited as much as possible. For construction products a guidance for the selection and use of generic data is provided in CEN/TR 15941.

The study should clarify how the lack, if any, of data has been made up for. The sensitivity analysis should focus precisely on this type of data. The impact of unselected generic data should not exceed 10% of the total impact.

Allocation rules applied: for non construction products allocation rules applied in accordance with ISO 14040 and ISO 14044 standards as well as the applicable PCR. As a general rule, allocation should be avoided, using specific data. If it cannot be avoided, the rules used should be tailored to the physical/economical phenomenon described as much as possible.

For Construction Products the rules provided in paragraph 6.4.3 of EN 15804 shall be applied. For both products type, whenever different kind of products come from manufacturing processes and only aggregate information are available, specific allocation rules must be defined for any single product. The PCR has to define the allocation method for each product. Allocation rules for waste treatment impact are set according to the figure 1.

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Process to be included into waste generator scope

Figure 1 - Process generating wastes: allocation rules

Waste management. Unless otherwise specified by the PCR, the final treatment of waste (landfill and incineration) whose production is connected with the product life cycle, should be included in the study. If this is not possible due to the lack of information, the amount of waste produced must be declared. For waste recovery and recycling processes, the Organisation should consider the sole impacts associated with the transport of waste to the waste treatment platform. The impacts of recycling (including, for example, composting or anaerobic degradation for the production of biogas) and thermal recovery processes, as well as the benefits arising therefrom, must be included in the life cycle where the recycled materials are reused and where the heat produced is recovered, respectively. However, the potential benefits arising from waste recycling and/or recovery can be indicated in the EPD section on additional environmental information. Definition of the scenario relating to end of life. Since these assumptions generally refer to scenarios which, in reality, can be very different from one another, the Organisation needs to identify average representative conditions and must carry out a sensitivity analysis on the different options identified thereby. The options identified might be linked to the geographical boundaries of the study, to the fact that the product covered by the EPD is a B2C or B2B product. The PCR might provide specific indications to identify the most appropriate scenario. For construction products, reference is made to the “polluter pays” principle, as specified in Table 2 of the CEN/TR 16970 standard.

Process generating wastes

Waste destruction

Incineration process

Energy use and distribution

Landifill

Scarp collection and selection

Recycling/reusing

Recycling/reusing

Stabilizing process Treatment of stabilised wastes

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By-products. The production of any by-products in the manufacturing of the product covered by the EPD is important in order to set the allocation rules. Indeed, if the process leads to the simultaneous production of by-products, the impacts deriving from the process must be broken down in relation to both products and by-products. The definition of a by-product follows that of Directive 2008/98/EC and can be summarized in the following points:

o it is a something whose production derives from the same process that leads to production of the product covered by the EPD.

o It originates from the production process, of which it is an integral part, whose primary purpose is not to produce such substance or object. The substance or object can be used directly without any further treatment other than customary industrial practice.

o Its further use is legal, i.e. the substance or object meets, for its specific use, all the relevant conditions on products and the protection of health and the environment, and does not cause overall adverse environmental impacts on the environment or health.

o It is certain that the substance or object will be used, in the course of the same or of a subsequent production or use, by the producer or a third party.

The presence of by-products must be documented in the EPD, reporting:

o the quantity of by-products for each functional unit of the product covered by the EPD o the allocation rules o the name of the by-product o its intended use o the criteria used to define it as a by-product.

GWP. PAS 2050 and ISO 14067 standards are the applicable standards to calculate the Carbon Footprint.

For EPDItaly Programme PAS 2050:2011 is taken as the basic reference, both Construction and NOT Construction Products.

PAS 2050 can be also considered as the main reference document for the calculation of the GWP100 in the preparation of the PCR.

For Construction Product see also table C.7 and C.8 of EN 15804.

For construction products with stored biogenic carbon, see EN 16485 “Round and sawn timber – Environmental Product Declarations – Product Category Rules for wood and wood-based products for use in construction” standard.

Emissions and removals of greenhouse gases must be accounted for the GHG emissions of the assessed product. Emissions and removals coming from fossil or biogenic sources as well as from direct land use change must be included. Concerning feed and food, emissions and removals due to biogenic sources becoming part of the product must not be taken into account with the following exception:

- Biogenic material that is part of the product but is not to be ingested

- Non-CO2 GHG gas coming from degradation of food and feed and enteric fermentation

- Emissions and removals of biogenic carbon due to the production of food and feed whenever the biogenic carbon doesn’t become part of the product.

Water Footprint. In the cases related to animal and vegetable biomass production processes, the indication of the product footprint (measured in relation to water consumption or ecological footprint) can be meaningful. When preparing the specific PCR, it is thus appropriate to refer to the Water Footprint Network (www.waterfootprint.org) and the Global Footprint Network (www.footprintnetwork.org).

5.10 ADDITIONAL REQUIREMENTS

When the recipient of the EPD is not necessarily a company (Business to Business B2B communication) and may be the final consumer (Business to Consumer B2C communication), the following additional requirements must be applied to the EPD.

Declaration that gives reasons for the omission of certain stages of the life cycle (for example, use and end of life) where no specific information is available or where these stages can reasonably be considered as negligible.

The Organisation must ensure that the EPDs intended also for consumers are available at the point of purchase of the product.

The Organisation must provide all additional explanations to clarify the content of the EPD. The cost of sending such material should be borne by the Organisation or should be limited, in any case, to any mailing costs where sending is not by email. The Organisation must ensure that the internal manager who is entrusted with providing such information, is indicated in the EPD and/or can be contacted at all the points of sale of the product.

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If the EPD is intended also for consumers, the Organisation must involve consumer representatives (for example, consumers' associations) and representatives of environmental interests (for example, environmental associations) in the PCR open consultation stage. In this case, the Advisory Board will identify and see to the participation of these stakeholders.

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C h a p t e r 6

E P D P u b l i c a t i o n p r o c e s s

6.1 PROCEDURE FOR THE SUBMISSION OF THE PUBLICATION REQUEST (APPLICATION FORM)

When an Organisation intends to publish an EPD, it addresses EPDItaly (www.epditaly.it) sending:

a. the EPD; b. the validation certificate received from the Certification Body; c. the verification report by EPDItaly, available on www.epditaly.it; d. the Application Form by EPDItaly, available on www.epditaly.it.

The Technical Secretariat, after receiving the Application Form, checks the documentation received and, after establishing its completeness, accepts the publication request.

EPDItaly after checking the consistency of the documentation received, takes a resolution for the publication of the EPD. The EPDs will remain published on the website of EPDItaly (www.epditaly.it) for as long as the Company pays the annual maintenance fee and gives proof of validity of the EPD, by confirming the validity of the validation certificate. EPDItaly may provide for cancellation from the registry for the reasons specified in § 6.4.2. All data and information relating to the EPD acquired by EPDItaly in the course of its publication activity, are confidential.

6.2 FEES

Registration and maintenance fees apply in relation to EPD publication. These fees are available on website www.epditaly.it. The registration fee must be paid before registration and publication of the EPD, while the maintenance fee must be paid at the beginning of the solar year, after invoice.

6.3 PUBLICATION

Once EPD publication has been resolved, the Technical Secretariat confirms the registration number that was preassigned at the time of acceptance of the publication request. The publication lasts until the date of expiry of the EPD at the most.

6.4 CANCELLATION OF THE PUBLICATION BY THE ORGANISATION, SUSPENSION AND REVOCATION OF

THE PUBLICATION

6.4.1 CANCELLATION OF THE PUBLICATION BY THE ORGANISATION

The Organisation may at any time cancel EPD publication within the EPDItaly Programme. In this case, the legal representative will send a written notice, signed thereby, to the Technical Secretariat. No fine applies in case of such cancellation. In any case, the fees for the year in progress must be settled. Such cancellation is effective from the date indicated by the Organisation and may not be earlier than that of receipt of the aforesaid notice.

As from cancellation, the Organisation can no longer use the EPDItaly logo (see § 7)or refer to EPD data by using the registration number which has been cancelled.

6.4.2 EXPIRY OF THE PUBLICATION

The Organisation might let the publication of its EPD expire without providing for its renewal.

In this case, paragraphs 3.15 and 6.4.1 apply.

6.4.3 SUSPENSION AND REVOCATION OF PUBLICATION

EPDItaly may decide to suspend publication in the following cases:

delay in payment of the fees due to EPDItaly for publication, after receiving a first payment reminder;

information received from the verifier relating to what has arisen in the course of a certification and/or maintenance audit;

outcome of arbitration proceedings in case of disputes (see § 6.5);

irregularities on the part of the Customer with respect to the use of the EPDItaly logo;

failure by the Customer to fulfil a contractual obligation;

where the Customer is protested or liquidated or involved in executive and/or insolvency proceedings;

suspension of the validation certificate by the Certification Body;

failure to communicate any judicial proceeding and/or administrative proceeding;

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existence of a judicial proceeding and/or an administrative proceeding or suspension/revocation of existing certificates that could damage the credibility of the publication;

any other case in which anomalies arise of a technical nature relative to the published EPD.

From the moment of suspension, the Organisation can no longer use the EPDItaly logo (see §7) or refer to EPD data by using the registration number.

EPDItaly may decide to revoke publication in the following cases:

non-payment of registration fees, after receipt of a specific prior notice sent by the Organisation;

outcome of arbitration proceedings in case of disputes (see § 6.5);

continuation of the reasons that have caused suspension of the publication;

where the Customer is protested or liquidated or involved in executive proceedings;

change in the applicable technical standards without these being accepted by the Customer;

final sentence against the Customer (res judicata) in judicial proceedings (including arbitration proceedings) for facts concerning non-compliance with these Regulations;

serious irregularities with respect to the use of the EPDItaly logo;

revocation of the validation certificate by the Certification Body;

expiry of the validation certificate;

failure to communicate any judicial proceeding and/or administrative proceeding;

existence of a judicial proceeding and/or an administrative proceeding or suspension/revocation of existing certificates that could damage the credibility of the publication.

any other case in which anomalies arise of a technical nature relative to the published EPD.

From the moment of revocation, the Organisation can no longer use the EPDItaly logo (see §7) or refer to EPD data by using the registration number.

6.5 ARBITRATION PROCEEDINGS

EPDItaly ensures that the EPD verification process is in accordance with the provisions of these Regulations and PCR requirements. This should ensure uniformity in the verification of EPDs as well as the comparability between different documents belonging to the same product category.

However, in case of disputes or complaints concerning the validity and/or quality of the content of EPDs, these Regulations provide for the commencement of arbitration proceedings.

Any disputes arising between EPDItaly and the company asking for EPD publication will not be submitted to ordinary Courts and will thus be settled via arbitration proceedings conducted in accordance with the Italian Code of Civil Procedure and with the Regulations of the Arbitration Chamber of Milan, referring to the provisions of law on the merits of the dispute. The Arbitration Board will be made up of a sole arbitrator. The arbitration proceedings will take place in Milan.

The arbitration proceedings are defined in the General Contract Conditions with the Organisation.

6.6 APPEALS

The Company may bring a grounded appeal against EPDItaly resolutions.

The terms and conditions of these appeals are defined in the General Contract Conditions with the Company.

6.7 COMPLAINTS AND GRIEVANCES

Any complaints and grievances relating to the activities of EPDItaly or the Company can be addressed to EPDItaly by the Customer and by third parties referring to the General Contract Conditions with the Organisation. The description of the complaints and grievances process is given to those applying therefor.

6.8 MUTUO RICONOSCIMENTO

EPDItaly may publish EPDs coming from other Program Operators with which it has a mutual recognition agreement, without demanding any additional verification. These EPDs must have EPDItaly’s cover (see Annex 2) and are subject to the application of this art. 6 and of art. 7 below.

EPDs coming from a mutual recognition agreement with Eco Platform members are subject to the attribution of the EPDItaly logo, since the technical analyses underpinning mutual recognition agreements verify the skills, independence and

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impartiality of the verifiers of the EPD coming from a mutual recognition agreement. The website www.epditaly.it will specify that the EPD derives from a mutual recognition agreement.

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C h a p t e r 7

E P D I t a l y l o g o

7 USE OF THE LOGO

The logo of the EPDItaly Program is shown below:

The logo may be used as follows:

in the EPD without any further specification;

on the product and on packaging materials, indicating also the EPD registration number, the date of registration

and the date of validity, the number of CPC code;

where the information drawn from the EPD is used in information materials, brochures, booklets, data sheets, etc.,

the Organisation must specify that the information is taken from the EPD. In this case, the Organisation can use

the logo and must refer to the EPD registration number, the date of registration and the date of validity, the

number of CPC code;

the EPD can be used only with reference to the EPD registration number, the date of publication and the website

of the EPDItaly Programme manager.