When preparing a PEP ecopassport®, the first challenge is often not to calculate the environmental impacts, but to define what the declaration can credibly represent. This requires an understanding of the product catalogue, identifying the technical differences between commercial references and determining which characteristics influence environmental performance.

The information required is generally spread across product bills of materials, ERP systems, product specifications, supplier declarations and test reports, which were originally created for purposes other than LCA. The PEP must therefore translate this existing technical reality into a robust environmental model.

The PEP ecopassport® reference framework provides rules for this process. The applicable PCR and PSR, the definition of a homogeneous environmental family, the selection of representative products and the establishment of justified extrapolation rules determine whether a single PEP can cover one product reference or an entire product range. In practice, these decisions may require more technical judgement than the calculation of the environmental indicators themselves.

The applicable rules are defined before the model is built

---

PEP ecopassport® is a Type III environmental declaration programme operating in accordance with ISO 14025 and dedicated to electrical, electronic and HVAC-R products. The underlying LCA follows EN 50693, which establishes product category rules for the life cycle assessment of electrical and electronic products and systems.

A PEP should therefore be understood as a sector-specific form of Environmental Product Declaration developed within the PEP ecopassport programme. Its specificity lies in the programme rules, product-specific requirements, publication system and verification framework applicable to these product categories.

Within the programme, the common Product Category Rules establish the requirements applicable to all covered products. These common rules may be supplemented by Product Specific Rules, or PSRs, developed for specific product categories. A PSR may specify the functional unit, reference service life, use scenario, technical assumptions and, where applicable, the extrapolation rules at product range level.

This has direct implications for modelling. Two products may both belong to the electrical equipment sector while relying on significantly different assumptions because they fulfil different functions and are governed by different PSRs. A cable, an electrical distribution device and a water heater do not necessarily require the same reference scenarios simply because they are all covered by the PEP ecopassport programme.

The identification of the applicable PCR and PSR is therefore not simply a preliminary administrative step. It establishes the methodological framework within which the product data will subsequently be interpreted.

This is particularly important when a declaration is intended to cover several commercial references. Some PSRs already define extrapolation principles for the corresponding product category. Where this is the case, part of the relationship between the reference product and the other products in the family is already specified. Where no such rule exists, this relationship must be developed and justified as part of the study.

A commercial product family is not automatically a homogeneous environmental family

---

The PEP ecopassport® PCR distinguishes between a unitary declaration covering a single commercial reference, a product family declaration covering several references from the same manufacturer, and a joint declaration covering products from several manufacturers.

For manufacturers managing extensive product catalogues, the product family declaration is particularly important. Producing a separate environmental declaration for each reference would often be inefficient when products share the same function and technical architecture. Conversely, applying the same environmental result to an entire commercial range would not be defensible if the products have differences that significantly affect their environmental performance.

The programme addresses this issue through the concept of a homogeneous environmental family.

Products grouped within such a family must share the same main functionality, comply with the same product standards and rely on similar manufacturing technologies, particularly with regard to material types and manufacturing processes. These criteria may seem straightforward, but their practical application requires a detailed understanding of the products. The structure of a commercial catalogue and that of an environmental family may therefore differ.

A manufacturer may market twenty references under the same product name and offer them within the same configurator. However, one variant may use an aluminium casing rather than steel, include an additional electronic board or rely on a different cooling architecture. From a commercial perspective, it remains part of the same range. From an environmental modelling perspective, it may require separate treatment.

The reverse situation is also possible. Products marketed under different commercial identities or distributed in different markets may belong to the same environmental family if their function, technical architecture, materials and manufacturing method remain sufficiently similar.

The relevant question is therefore not whether the products appear similar in the catalogue, but which technical differences explain their environmental differences.

Product data becomes useful when it explains environmental variations

---

Once the potential family has been defined, the next step is not simply to transfer the product data into an LCA model. The most important question is to determine which technical characteristics explain variations in environmental performance across the range.

Mass, rated power, dimensions, material composition, cooling architecture, electronic content and use characteristics can all become parameters of the environmental model. However, these parameters should only be considered as extrapolation variables when it is possible to demonstrate their relationship with environmental performance.

Let us take the example of a range of electrical equipment available with several power levels. As the rated power increases, the total mass of the product may also increase, but the relationship between power and environmental impact is unlikely to be strictly proportional.

The amount of copper may increase more rapidly than the mass of the casing. The same electronic assembly may be used for several power levels before changing above a certain threshold. Packaging may depend mainly on the external dimensions rather than the rated power. Losses during the use phase may follow a completely different relationship, while efficiency may improve as the product size increases.

Applying a single scaling factor to the entire environmental profile would therefore mean combining several distinct physical relationships into a single coefficient and could mask significant discontinuities within the product range.

This issue is also being studied as part of naKnow, a collaborative initiative examining how product-specific technical characteristics can improve the environmental inventories of electronic components. In this project, we are studying why the environmental inventories of bare electronic boards, semiconductors, displays and other electronic components often fail to distinguish between technically different products. For example, two bare electronic boards described by the same number of layers, the same type of substrate and the same surface finish had measured copper concentrations that differed by a factor of approximately two. Conventional descriptors did not make it possible to account for characteristics such as copper coverage, stack-up or metallised surface.

The implications for PEP modelling are similar. A parameter is not necessarily useful simply because it is readily available in the manufacturer’s information system. It becomes useful when it helps explain environmental variations.

Extrapolation must be demonstrated rather than assumed

---

When a PEP covers several references, extrapolation is not simply a practical shortcut. It is part of the methodological justification for the declaration. The general approach is to examine the products in the proposed family, assess representative references, identify the technical parameters that vary within the range and determine which of these parameters have a significant influence on the environmental results. Extrapolation rules can then be established based on these relationships. The choice of representative products deserves particular attention.

Representativeness can be defined technically, for example by selecting a product located around the centre of the range, or commercially, by selecting a product representing a significant share of sales. These approaches do not necessarily lead to the selection of the same reference and should not be considered equivalent without justification.

Where no specific extrapolation rule is provided by the applicable PSR, examining products close to the upper and lower boundaries of the family, together with an intermediate reference, can provide an important test of the proposed model.

Let us take a range from 2 kW to 20 kW. A 10 kW product may initially appear representative. However, products at the boundaries of the range may reveal structural changes that are not visible around the centre of the range: forced cooling may appear above a certain power level, the control board may change, or packaging and transport conditions may evolve when certain dimensions are exceeded.

In such cases, a single continuous extrapolation rule may no longer correctly describe the family. The appropriate response may be to divide the range into several modelling domains or to define a more restricted homogeneous environmental family.

The PCR allows for different approaches to presenting extrapolated results. A declaration may use a conservative result corresponding to the product with the highest impact, provide extrapolation coefficients specific to each reference or apply calculation formulas. However, the approach selected must remain justified by the structure of the product family.

These relationships must remain relevant across the different stages of the life cycle.

A parameter such as product mass may provide a reasonable basis for modelling part of the manufacturing stage, but may be less suitable for distribution and completely inappropriate for the use phase of an energy-consuming product. Extrapolation must therefore reflect the physical mechanisms governing each stage rather than relying on a single overall assumption of proportionality.

The reference product should therefore be considered as the anchor of the environmental model, rather than as a proxy whose result would simply be multiplied to generate the results for the other references.

The credibility of the product family declaration depends on demonstrating that the relationships established between the reference product and the other products remain valid across the entire range covered by the PEP.

Building the model requires technical knowledge of the product range

---

Engineering teams understand why a technical parameter changes at a given power level or configuration. Procurement teams know whether material grades, suppliers or sub-assemblies differ between references. Product teams can distinguish between products that are actually marketed and references that remain in internal systems but are rarely, if ever, sold.

These distinctions can have a significant impact on the environmental family. A variation in mass may result from a larger casing, a different metal, an additional component or a structural modification to the product architecture. These situations may produce similar values in an ERP extraction while requiring very different environmental interpretations.

For this reason, data collection for a PEP should not be considered as simply requesting a predefined list of fields. The most important task is to understand the technical relationships represented by these fields. In practice, this step often determines the duration and robustness of the study.

The LCA report and the published PEP serve different purposes

---

The published PEP does not constitute the entire technical documentation of the assessment. The programme distinguishes between the LCA report, which documents the inventory, data sources, methodological choices, assumptions, calculations and detailed results, and the PEP, which communicates the environmental information in accordance with the programme’s publication requirements. This distinction is particularly important for a product family declaration, as the technical justification for the family is mainly documented in the LCA report: how the scope was defined, which products were selected as representative, which parameters were assessed, how environmental sensitivity was examined and how the extrapolation rules were established.

The published declaration presents the products covered, the environmental results and the applicable extrapolation information, without reproducing the entire analytical reasoning behind the model. Independent verification therefore examines whether this work complies with the programme requirements, rather than simply checking that the environmental indicators have been correctly transcribed into the final document. The definition of the family, the representativeness of the products assessed, the modelling assumptions and the extrapolation logic must all be sufficiently documented to allow for an independent review.

The LCA report should therefore be considered as technical evidence rather than simply as an internal calculation note. The methodological and practical questions raised by independent verification deserve separate consideration and will be addressed in a dedicated article. Les questions méthodologiques et pratiques liées à la vérification indépendante méritent toutefois un traitement distinct et seront abordées dans un article dédié.

From the catalogue to the environmental family

---

The distinctive aspect of preparing a PEP ecopassport is not the requirement to carry out an LCA. This requirement is fundamental, but it is not what makes the programme operationally specific.

For manufacturers with extensive product portfolios, the main challenge lies in how the PEP reference framework links commercial references to a defensible environmental family and defines the conditions under which environmental results can be extrapolated across that family.

For a declaration covering a single product, this issue remains relatively limited. For a manufacturer managing dozens or hundreds of related references, it becomes central to the credibility and efficiency of the approach.

The quality of the declaration therefore depends on several interrelated questions: has the environmental family been correctly defined? Do the representative products adequately describe the range? Do the selected technical parameters actually make it possible to explain environmental variations? And do the extrapolation rules remain valid for all references included in the PEP?

At WeLOOP, this approach is at the heart of how we carry out PEP ecopassport studies. The objective is not to fit a commercial range into a predefined average model, but to understand its technical structure well enough to determine where a common environmental model remains valid, where extrapolation is justified and where a change in technology or configuration requires separate treatment.

The published PEP may ultimately contain a relatively limited set of environmental indicators. However, a robust product family declaration is based on something more substantial: a demonstrated relationship between the technical variations within the product range and the environmental performance attributed to it.