Assessing the completeness and comparability of environmental product declarations

More environmental product declarations (EPDs) have been published in recent years, but type III declarations still have limitations, for example regarding comparability. According to ISO 14027, a comparative disclaimer addresses the equivalence between a given product and a competing product that performs the same function. ISO 14025 states that EPDs developed under the same rules can be compared, but previous research has found that even EPDs developed using the same rules cannot be used for comparison. This paper evaluates the rates of comparability between EPDs developed within the scope of the same product categories and their respective product category rules (PCRs), sub-PCRs, and program operators. For the initial analysis, the International EPD System (IES) and the Institute Bauen und Umwelt e.V. (IBU) were selected and two product categories defined from each program for a total of four categories: boards and thermal insulation from IES, and floor covering and thermal insulation from IBU. Then, the completeness of the reported information according to the requirements from ISO 14025 was assessed. The final step compared EPDs developed using the same rules and calculated the rate of comparability between documents. Comparability between two EPDs was classified into three levels (fully comparable, comparable with caution, and cannot be compared). From the four product categories, 436 EPDs were selected, each based on one PCR/sub-PCR. Only 5.04% of the EPDs presented all the mandatory information required; this lack of information affected comparability, since items that are not reported cannot be compared. This, together with flexible definitions of some elements (such as functional/declared units, allocation procedures, and cut-off rules) in the PCRs led to low rates of comparability. Of all the potential comparisons, 8.06% of the documents could not be compared in any aspect, 89.15% were considered incomparable, 2.75% could be compared with caution, and only 0.04% were comparable.