Program Operator vs. Verifier: What Every Manufacturer Should Know

New to EPDs? This guide breaks down the roles of Program Operators and Verifiers so you can publish accurate, trusted declarations with confidence.

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As a manufacturer, you’ve decided to start providing Environmental Product Declarations (EPDs) for your products. So far, an LCA practitioner or consultant has helped you map the production process, gathered relevant data, and prepared the Life Cycle Assessment (LCA) report. The next step is verification, which raises the question: who handles this, and how? This brings two key roles into focus: the Program Operator and the Verifier.

Think of a program operator as an organizer and gatekeeper of the EPD system. They oversee the guidelines that ensure EPDs are created and published in a consistent way.

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Technically speaking, a Program Operator (PO) is the organization - often an NGO or governmental body - responsible for managing the overall system for producing and publishing Type III Environmental Product Declarations (EPDs), in accordance with ISO 14025. For construction products, the PO ensures alignment with EN 15804, which provides specific rules for LCA and environmental impact indicators.

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PO Examples: IBU (Germany), The International EPD System (Sweden), EPD Norge (Norway), INIES (France)

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1. Developing and maintaining the EPD process: Establishes and manages the EPD framework according to ISO 14025.
2. Product Category Rule (PCR) development: Coordinates the creation or adoption of PCRs that specify the LCA methodology for each product type, including system boundaries, functional unit, and impact categories—based on standards like EN 15804 or ISO 21930.
3. Verification system management: Designs the verification procedures, ensuring each EPD is reviewed by a qualified, independent third-party for compliance with the PCR and ISO 14040/14044.
4. Verifier approval or accreditation: Appoints or recognizes competent verifiers based on defined criteria.
5. EPD publication: After successful verification, registers and publishes the EPD in a public platform, ensuring transparency and traceability.
6. Ongoing system updates: Maintains and improves program documents, PCRs, and procedures as standards evolve.

‍If the Program Operator sets the rules, the Verifier ensures the rules are followed. Think of them as a third-party fact-checker for environmental product data.A Verifier performs an independent review to ensure that the specific EPD or EPD Tool is:• Consistent with the applicable PCR• Compliant with LCA standards such as ISO 14040/14044 and EN 15804• Transparent and not misleading

1. Whether the LCA methodology is appropriate
2. The data quality is sufficient—meaning representative, consistent, complete, and well-documented.
3. The impact assessment results are correctly calculated and reported
4. That all mandatory EPD elements (as specified by the POs) are present

Importantly, Verifiers must be independent and qualified, approved by the Program Operator (often multiple POs). Their impartial review adds credibility and ensures the EPD meets internationally recognized requirements before publication.

Once the Verifier confirms that the EPD meets all requirements, it’s sent back to the Program Operator for official publication.

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Working on your first EPD? Emidat helps you structure your data correctly so it’s ready for verification and publication.