May several similar products be included in the same EPD?

Rules for including multiple similar products in the same EPD can be found in Section A.9.1 of version 5.0.0 of the General Programme Instructions (GPI). For older versions of the GPI, the rules can be found in other sections. 

Note that a specific PCR may include deviations or specifications to these rules. Further, some PCRs are based an old GPI) in which the rules may be different from the current version - we still recommend following the current version as long as the rules are not in conflict with the PCR used, as all PCRs will be updated according to these rules. 

Several sets of results, reflecting different products, shall not be declared in the same EPD. However, similar products may be grouped and thereby included in the same EPD under one set of results. Similar products are defined as products covered by the same PCR, with identical or similar functions, manufactured by a single company at one or several manufacturing sites, with the same major steps in the A3/core processes.  For such an EPD, there are three options: 

• For each indicator, declare the average results of the included products. This average shall be weighted according to the production volumes of the included products, if relevant. In this option, the average content shall be declared in the content declaration. 
• Declare the results of one of the included products or the average of a subset of the included products, i.e., one or several representative products. The choice of the representative product(s) shall be justified in the EPD, for example based on production volumes. In this option, the content of the representative product, or the average of the representative products, shall be declared in the content declaration. 

For each indicator and module A-C, declare the highest result of the included products, and for module D, declare the lowest benefit of avoided processes (or highest drawback of compensating processes, see Section A.7.5) and the highest load of included processes. This options thus corresponds to the results of a “worst-case product", which may be consists of results from one or several of the included products. In this option, the content declaration shall include the lowest amounts of recycled and biogenic content of the included products and their packaging, respectively, and the information on environmental and hazardous properties of substances shall reflect the highest share and most hazardous such substances contained in the any of the included products. 

For all options, the range of the content of the included products should be included in the content declaration, in addition to the average/representative/worst-case content as specified above.

For EPDs claiming compliance with ISO 21930, the above options are only possible if none of the declared environmental impact indicator results, aggregated over all included modules (from A to C), differ by more than 10% between any of the included products. In some PCRs, this is  a generally applicable restriction.

If the EPD does not claim compliance with ISO 21930, variations above 10% are allowed. In such cases, the LCA report shall include an explanation of the variation and a justification of the grouping of products, and the EPD shall (in the LCA information section) declare the variation of each impact indicator results for which the variation is above 10% and include an explanation of the variation. EPDs based on worst-case results, that do not claim compliance with ISO 21930, are exempted from the requirement to declare the variation if above 10%. 

The option chosen shall be clearly described at the cover page of the EPD, as “EPD of multiple products, based on the average results of the product group”, “EPD of multiple products, based on a representative product”, “EPD of multiple products, based on several representative products”, or “EPD of multiple products, based on worst-case results”. 

In addition to above options, sector EPDs are possible. See more in Chapter A.9.2 of the GPI and the applicable PCR.

If the PCR is based on GPI version 3.01 or older, the EPD may include several products/product groups even if above requirements are not fulfilled, but then the results of each product/product group shall be separately declared. If the PCR is based on the versions 4.0 or 5.0.0 of the GPI, the EPD shall include no more than one set of results (but for certain life-cycle stages, several sets of results may be declared; see applicable PCR). This change of rules was done to improve machine-readability of EPDs and thereby facilitate digitalisation of the EPD system. To enable this change, the cost per EPD registrations was reduced significantly as of 1st January 2021. Even if older versions of the GPI allow the declaration of results for several products/product groups, we recommend to declare no more than one set of results per EPD – to be well prepared for thee digital future. 

Note that it is not allowed to include a conversion factor in the EPD for the purpose of converting the declared results into results for products not covered by the EPD. The EPD is for a specific product or product group, and only the EPD content of that product/product group has been verified and may be considered EPD information. You may, however, include a conversion factor for other purposes, see the answer to the question "May conversion factors be included in the EPD?".