Date June 7, 2026

ISO 14025:2026 Is Here — Quietly Redrawing the Rules for EPDs, Tools, and Program Operators

A Smart EPD perspective on the first major revision of the EPD standard in twenty years.

After two decades, ISO 14025 has been rewritten. The 2006 edition, the document that gave the world “Type III environmental declarations” and, with it, the modern EPD, has been formally cancelled and replaced by ISO 14025:2026. Fabian Diaz, a Smart EPD Advisory Board member, and others in the LCA community have already flagged the headline structural changes, and they’re right that this is a consequential update. But the more time we spend inside the new text, the clearer it becomes that this isn’t just housekeeping. It’s a deliberate response to how the EPD market actually works in 2026: automated, tool-driven, commercially competitive, and under growing regulatory scrutiny. Below is our read on what actually changed and, more importantly, what it means for the people who make EPDs and the Program Operators who run the schemes.

A note on sourcing: out of respect for ISO copyright, we describe the changes and their implications rather than reproducing the standard’s text. If you operate a program or verify EPDs, please buy the document since this article is orientation, not a substitute.

The vocabulary changed, and vocabulary is policy

The most visible change is also the most symbolic: “Type III environmental declaration” is gone. The 2026 edition deprecates it — along with “environmental label” and “environmental declaration” — and standardizes on “environmental product declaration (EPD).” The old Type I / II / III taxonomy has been retired across the whole ISO 14020 family. The title of the standard itself changed to reflect this, dropping “Type III” in favor of “Environmental product declarations (EPDs).” This is welcome news. The old taxonomy invited abuse — including manufacturers marketing self-declared claims as “Type II EPDs,” a label that never actually existed and only sowed market confusion.

This matters more than it looks. For years, practitioners have used “EPD” colloquially while standards, PCRs, and procurement specs formally said “Type III.” Aligning the language removes a translation layer that caused real confusion in tenders, green building credits, and regulation. Program Operators will need to sweep their GPI, PCR templates, verification statements, and web copy to retire “Type III” — a small editorial job with a long tail across every published document.

Underneath the rebrand sits a structural realignment with the revised ISO 14020:2022, which is now the umbrella standard providing common terms, principles, and general requirements for all “environmental statements.” Content that used to live in ISO 14025’s principles and requirements clauses has been moved up into ISO 14020. The practical consequence: you can no longer read ISO 14025 in isolation. It’s now explicitly a specialization of ISO 14020, and it pulls ISO/TS 14027 (PCR development) and ISO/TS 14029 (mutual recognition) in as normative references. The standard has become a hub in a network rather than a standalone rulebook.

The definitions section grew accordingly — reorganized into environment, EPD/programme, life cycle, and conformity-assessment groupings — and picked up a raft of new or sharpened terms:

General programme instructions (GPI)
EPD tool
Declared unit — now formally defined, not just referenced
Environmental performance
Predetermined impact indicators and predetermined inventory indicators — replacing the vague 2006 phrase “predetermined parameters”
Sustainability-related information
A full chain of custody vocabulary borrowed from ISO 22095

That last one is a signal in itself: mass balance, credit method, and book-and-claim are now first-class concepts the standard expects programs to address.

The structure now mirrors how EPDs are actually produced

Three structural moves stand out in particular.

First, the old “declaration requirements” clause has been split into general requirements (aligned to ISO 14020) and EPD program specific requirements. This separates “what any environmental statement must do” from “what an EPD in a scheme must do” with cleaner logic, and easier to keep in sync as ISO 14020 evolves.

Second, and truly new, is a dedicated clause requiring Program Operators to define EPD types. Rather than treating every EPD as interchangeable, the standard now expects programs to classify declarations along parameters like:

The number of products, companies, and manufacturing facilities covered;
The percentage of the GWP result derived from supply-chain-specific data;
Which life cycle stages are included;
How many consecutive months of specific data underpin the LCA.

The type has to be declared in the EPD itself. It also formalizes prospective EPDs, intended for products recently launched or not yet on the market, by providing guardrails of limited validity, mandatory re-evaluation after a year, clear labeling to avoid confusion, and quantification of uncertainty.

This is a quiet but important shift toward comparability with honesty. A single-product, single-facility EPD built on twelve months of primary data is a very different object from an industry-average declaration leaning on generic background data, and now the EPD has to say so on its face. For anyone in procurement or benchmarking, that’s a meaningful upgrade in signal quality.

Third, a new informative annex addresses harmonization of PCRs and EPD programs for comparability, tied to ISO/TS 14027 and 14029, and mutual recognition arrangements (MRAs) are woven through the operator requirements. Comparability has moved from aspiration to process.

The part everyone will argue about: independence

Here is where the 2026 edition has real teeth. The definition of “third party” carries the same core wording as before — independent of the parties involved — but the accompanying note now spells out who those parties are. And the list is pointed: the responsible party (the manufacturer or EPD owner), the Program Operator, the LCA practitioner, and — explicitly — EPD tool developers.

Read that again, because it’s the sentence that will reshape verification schemes. For a verifier to be a genuine third party under ISO 14025:2026, they must be independent not only of the manufacturer but of the program and of the company that built the EPD tool. The standard also folds independence directly into the definition of verifier itself, which now reads as a “competent and independent” person or persons — where 2006 simply described someone who “carries out verification.”

The practical target is obvious to anyone who has watched the market: arrangements where verifiers were trained, approved, or effectively supplied by the same EPD tool they were checking, or where an in-house reviewer at an EPD owner was still badged as a “third party.” Those models are now hard to square with the text. The standard reinforces the point elsewhere:

PCR review and EPD verification must be two separate processes;
The PCR review panel needs at least a chair plus two members;
Program Operators must establish and implement policies to identify, disclose, and manage conflicts of interest across operators, verifiers, and panel members.

We’ll be candid about where Smart EPD sits in this. We work with tools that automate EPD generation, so the tool-independence language points squarely at our corner of the industry. Credibility is the entire value proposition of an EPD. A number nobody trusts is worse than no number at all. A standard that draws a bright line between the people building the calculation engine and the people checking the output protects the currency we all trade in. The design question for tool developers isn’t “how do we get around this,” it’s “how do we make our tools so transparent and well-documented that independent verifiers can check them efficiently, without ever being on our payroll.”

EPD tools finally exist in the standard (with strings attached)

For the first time, ISO 14025 acknowledges that EPDs are increasingly generated by software. It defines “EPD tool,” and it builds a verification pathway around it: Program Operators must specify requirements for verifying EPD tools, and a verified tool can unlock a simplified, streamlined verification process for the individual EPDs it produces. The GPI must describe EPD tool verification explicitly.

This is a big deal for the digitization of EPDs. It rewards the pre-verification of a tool — check the engine once, rigorously, and every declaration it produces inherits that assurance — which is exactly the model that makes EPDs affordable at scale under the Smart EPD program and others. But it also pairs the efficiency with the independence requirement above. The message to the market is coherent: automation is welcome, provided the automation is independently verifiable and the verifier isn’t the vendor. It’s a requirement we already meet, and one we’re committed to upholding as the standard rolls out.

Program Operators have the most work to do

If EPD owners feel the terminology and type-declaration changes, Program Operators will feel almost everything else. The 2006 edition gave POs a fairly compact list of duties. The 2026 edition expands it dramatically into a long, explicit governance checklist. Among the additions POs now have to satisfy:

Disclose their ownership structure, governance, and revenue mechanisms, and put procedures in place so that revenue can’t compromise impartiality.
Publish GPI on an electronic platform and maintain publicly available digital registries of PCRs and EPDs.
Operate transparent PCR development — voting procedures, dispute resolution, public consultation before publication, and objective advisory committees.
Maintain a complaints procedure, including for errors found in already-published EPDs.
Adopt a competition / anti-trust policy communicated to all interested parties.
Actively participate in MRAs under ISO/TS 14029 to drive cross-program recognition.

Taken together, this reads less like a labeling standard and more like a governance regime for a regulated market — which, given where US state and EU product and green-claims regulation is heading, is almost certainly the point. POs whose business models blur the lines between running the scheme, selling the tool, and supplying the verifier will have the steepest adaptation curve. POs who already run transparent, arms-length governance, such as Smart EPD, will mostly be formalizing and publishing what they already do.

What we’re watching

The open question is adoption speed. ISO 14025 is voluntary, and there’s no switch that flips every PCR and GPI overnight. Realistically, we expect a staggered transition: POs updating GPI and terminology first, then reworking verifier approval and tool-verification procedures, then unwinding any conflict-of-interest arrangements that the new “third party” definition no longer permits. The B2C corner tightens immediately — for consumer-facing EPDs, all verification must be third-party and the verifier named in the declaration.

Our take at Smart EPD is that 2026 pushes the market in the direction it needed to go anyway: clearer language, honest typing of what an EPD actually represents, genuine independence in verification, and formal recognition that tools (properly verified by people who don’t work for the tool vendor) are how EPDs scale. The disruption will be real for some schemes. But a standard that makes EPDs harder to fake and easier to compare is a standard worth adapting to. We’d rather build for that world than the one we’re leaving behind.

Questions about how ISO 14025:2026 affects your EPD, PCR, or your verification pathway? That’s the conversation we’re here for at sales@smartepd.com.