PEP ecopassport®: what does the independent verifier actually check?
Naeem Adibi & Anish Koyamparambath
A PEP ecopassport® is more than just an environmental results sheet. Before it is registered, a person authorised by the programme reviews the underlying study and checks the consistency of the information intended for publication. For manufacturers, understanding this stage makes it possible to prepare the right information from the very beginning of the project.
In our previous article on product ranges, we showed how several product references can be covered by a single PEP when their grouping and extrapolation rules are justified. This naturally raises a question: how is this justification checked? Independent verification provides the answer.
Who can verify a PEP?
The verifier must be approved by the PEP ecopassport® programme and hold a valid approval. They may work within the company or externally, but must be independent of the LCA and the preparation of the PEP they are reviewing. The programme publishes a list of approved verifiers. The manufacturer therefore selects a qualified verifier and arranges access to the necessary information, including where certain industrial data are confidential: the verifier is bound by confidentiality.
What exactly does they look at?
The AP0002 verification procedure distinguishes three areas: the Life Cycle Assessment (LCA) methodology, the plausibility of the results, and the accuracy of the information published. The review therefore goes beyond simply checking the final PDF.
The verifier relies on the supporting report, which documents the calculations underlying the PEP. In particular, they check the versions of the programme’s general rules (PCR) and the product category-specific rules (PSR), the reference product and functional unit, materials and components, data sources, as well as assumptions relating to manufacturing, transport, installation, use and end-of-life. Any exclusions and approximations must be explained. The calculated results must then correspond to the figures and claims presented in the published declaration. The AP0012 document details the expected content of this report.
Consider an electrical device whose energy consumption varies depending on its different operating modes. Declaring an annual value without explaining the measured power levels, operating times and the scenario used makes it impossible to understand the result. The manufacturer must provide this information, together with its link to the LCA model. For electronic components, uncertainties regarding composition or manufacturing processes may also be significant: we provide examples in our article on the lessons learned from the naKnow project.
What if a PEP covers an entire product range ?
The review also covers the product references actually included. The verifier must be able to understand why they belong to the same environmental family, why the reference product was selected, and how the results are calculated for the other product references. A simple commercial product list or a coefficient applied indiscriminately to all impacts is not sufficient to demonstrate a valid extrapolation.
For example, if a higher power rating requires an additional electronic board or a new cooling system, this technical change must be taken into account. The supporting report required under AP0012 requires the extrapolation rules applicable to the product family to be described, justified and documented. The manufacturer’s technical data therefore become useful evidence for verification, rather than merely inputs for calculations.
How does the review process work through to publication?
In practice, the manufacturer provides the verifier with the draft PEP, the supporting report and the information needed to trace the calculations. The verifier records their observations in a checklist. The team that conducted the study responds, provides any missing supporting evidence and, where necessary, corrects the model, report or declaration. This process may involve several rounds of exchanges, particularly when component data, use scenarios or the boundaries of a product range are not yet clearly defined.
At the end of the review, the verifier issues a verification report, which records the points reviewed and the responses provided, as well as a declaration of conformity. The verification report remains confidential. The declaration, the PEP and their identification information must be consistent. The PEP is then registered with the programme before it can be presented as a compliant PEP ecopassport®; it is assigned a registration number and includes the verification box required by the AP0008 editorial rules. The official “Declaring a PEP” page describes this process.