The PEP: An EPD-type environmental declaration

A common source of confusion

In practice, the terms “PEP” and “EPD” are often used as if they referred to two competing systems. In reality, there is no rivalry between the two: a PEP is an EPD. More precisely, a PEP is the declaration produced under the PEP Ecopassport® program, which is itself one of the international programs for creating EPDs.

What is an EPD?

An EPD (Environmental Product Declaration) is a standardized document that presents, in a transparent and verified manner, a product’s environmental impacts across its entire life cycle. It is also classified as a “Type III” environmental declaration under the international standard ISO 14025. This standard establishes the principles and procedures for developing this type of declaration, which is primarily intended for business-to-business communication.

In practical terms, an EPD is always based on the same foundations:

• a multi-criteria life cycle assessment (LCA), conducted in accordance with ISO standards 14040 and 14044;
• sector-specific methodological rules, enabling the comparison of similar products;
• verification by an independent third party, ensuring the reliability of the published data;
• international recognition, underpinned by compliance with ISO standards.

The term “EPD” therefore refers to a family of standards, not a specific program. There are numerous EPD programs worldwide, such as the International EPD System, IBU, EPD Italy, and, for construction products in France, the INIES program with its FDES declarations.

What is a PEP?

The PEP (Product Environmental Profile) is the environmental declaration issued under the PEP Ecopassport® program. It serves, in effect, as the environmental “identity card” for an electrical, electronic, or HVAC (heating, ventilation, and air conditioning) product. The PEP meets the exact requirements of an EPD:

• it complies with the ISO 14025 standard, as well as ISO 14040/44, EN 50693, and EN 63366;
• it is based on a multi-criteria Life Cycle Assessment (LCA) governed by sector-wide rules, Product Category Rules (PCR), which are further detailed into Product Specific Rules (PSR) tailored to each product category;
• it is prepared under the manufacturer’s responsibility and published on a voluntary basis;
• it undergoes independent verification, evidenced by a declaration of conformity and a verification report, before being registered with a unique number;
• it enjoys international recognition, bolstered by mutual recognition agreements (MRAs) between programs.

In France, this recognition has very tangible implications: the PEP Ecopassport® program has an agreement with the Ministry of Housing (DHUP), allowing PEP data to be used in building life cycle assessments required under the RE2020 environmental regulations. Furthermore, PEP data is automatically transmitted to the INIES database.

So, what is the difference?

While every PEP is an EPD, the reverse is not true: not all EPDs are PEPs. The distinction lies at two levels:

• “EPD” refers to the standards-based category: any document compliant with ISO 14025 can be classified as an EPD, regardless of the program under which it falls.
• “PEP” specifies the program and the application sector: the PEP Ecopassport® program, dedicated to electrical, electronic, and HVAC products, with its own governance rules, dedicated PCRs/PSRs, and verification process.

In other words, saying “PEP” is equivalent to saying “EPD produced within the PEP Ecopassport® program framework for an EEE or HVAC product.” It is a specification, not an exception.

Why this distinction matters

Understanding that the PEP is an EPD allows the program to be placed in its international context without downplaying its specific nature. This dual positioning is what makes the PEP Ecopassport® program strong:

• international credibility, as it is an EPD in the full sense of the term, recognized by ISO standards and mutual recognition agreements with other programs;
• sector-specific relevance, thanks to rules tailored to electrical, electronic, and HVAC products, a level of detail few generalist programs offer.

For manufacturers in the EEE/HVAC sector, publishing a PEP means producing a globally recognized EPD while benefiting from a methodological framework designed specifically for their products, one that can be directly utilized for French regulatory requirements like RE2020.

In summary