“State the carbon footprint in the DPP” - that sounds as if you simply have to enter a CO2 value. In reality there are seven different established methods, all of them supported by serious certifiers and industry associations. Which one the ESPR requires depends on the product.
A pragmatic overview of what distinguishes these methods and which one you need when.
The system-boundary question
A CO2 balance is meaningless without a system boundary. “Product X has a footprint of 5 kg CO2eq” is a statement without context. Five kilograms - measured up to where?
The three established system boundaries:
- Cradle-to-gate - from raw-material extraction to the manufacturer’s factory gate. Excludes transport to retail, sale, use and disposal.
- Cradle-to-grave - from cradle to grave. Includes the use phase and end-of-life.
- Cradle-to-cradle - cradle-to-grave plus the use of recyclate in the follow-up product.
The EU Batteries Regulation requires a consideration over the lifecycle. The ESPR is expected to require cradle-to-grave depending on the product category (the draft for textiles shows this).
ISO 14040/14044: the fundamental framework
ISO 14040 and 14044 are the standard for Life Cycle Assessment (LCA). They say how you set up an LCA, but not which specific rules apply to a particular product.
The logic:
- goal definition and system boundary
- inventory analysis (input-output analysis: material and energy flows)
- impact assessment (conversion into CO2eq, water consumption, etc.)
- interpretation and sensitivity
Calculated by an accredited LCA consultancy, an ISO-compliant study for a product typically costs 10,000 to 50,000 euros. The calculation is valid for 3 to 5 years, after which it has to be updated.
PEF: the ESPR choice
The EU has developed the Product Environmental Footprint (PEF) to create a uniform route. PEF builds on ISO 14040/44 but standardises many decisions:
- 16 impact categories (not only climate, but also water, resource use, acidification, etc.)
- defined calculation rules
- defaults for data gaps
For many product categories there are PEFCR - Product Environmental Footprint Category Rules. They are the “sheet music” for PEF: the refinement for the respective product category. As of 2026 PEFCR exist for leather, batteries, paints, dairy products and a few more; textiles and packaging are in development.
The ESPR builds on PEF. Anyone commissioning a carbon-footprint calculation today should ask the consulting firm whether it delivers PEF-ready.
EPD: the industry-established alternative
The Environmental Product Declaration (EPD, ISO 14025) is the form that dominates in the construction industry. It is also based on LCA, but follows EN 15804 (for construction products).
EPDs are issued by national programme operators - in Germany for example IBU, in Switzerland KBOB. Per product an EPD costs similar to a full PEF study, but the infrastructure is more established. Almost every manufacturer of cement, steel and wood already has EPDs.
The new Construction Products Regulation (EU) 2024/3110 makes EPDs mandatory for many construction-product categories and couples them to the “Construction Products Passport”. For building-material manufacturers: the EPD will not disappear, it will become the foundation.
Cradle-to-gate in practice: identifying hotspots
If you do not aim for the full programme but start pragmatically with a cradle-to-gate calculation, this is possible with considerably less effort. Common hotspots:
- steel: approx. 1.85 kg CO2eq per kg (primary steel), 0.3 to 0.5 kg (electric arc from scrap)
- aluminium: approx. 12 kg CO2eq per kg (primary), 0.5 kg (recycled)
- cement: 0.8 kg CO2eq per kg
- cotton: 10 to 30 kg CO2eq per kg textile unit, depending on origin and cultivation
- polyester: 3.5 to 6 kg CO2eq per kg
These values come from aggregated databases such as ecoinvent. For a first estimate a multiplication is enough: material weights times the CO2 factor from ecoinvent. For mandatory reporting that is not enough, but it helps to make internal decisions.
Which values must the DPP show?
Depending on the product category:
- batteries: CO2eq per kWh of battery capacity over the entire lifecycle
- construction products: PCR-based EPD result, impact categories following EN 15804
- textiles (draft): PEF value per kilogram of textile product
The unit matters. CO2 per item is usually not comparable, because product sizes vary. That is why it is always related to a functional unit - kg, m², kWh.
The most common mistake: requesting supplier data too late
The balance of an end product is built 70 to 85 per cent from supplier emissions. If your supplier has no LCA data, your end product has none either. Ask your top 10 suppliers for Scope 1 and Scope 2 emission data now, not six months before the ESPR deadline. The typical lead time to data provision in a B2B relationship is 9 to 18 months.
The Greenhouse Gas Protocol Scope distinction helps:
- Scope 1 - own direct emissions (combustion on site)
- Scope 2 - indirect emissions from purchased energy (electricity, heat)
- Scope 3 - everything else along the value chain (often 70 per cent and more of the total footprint)
Your suppliers usually have Scope 1 under control, Scope 2 is manageable. Scope 3 is the real problem - because your Scope 3 is their Scope 1+2. That cascades up the chain.
Pragmatic recommendation
If you are now considering which method to choose:
- construction products: EPD (mandatory anyway)
- batteries: PEF (mandatory anyway)
- textiles, electronics, furniture: PEF as a working hypothesis, with an eye on the delegated regulation for your product category
- everything else: ISO 14044 as a basis and, if needed, migrate to PEF or EPD
What you should avoid: a proprietary method that afterwards does not align with the ESPR format. That produces duplicate work.