Executive Summary

A product carbon footprint (PCF), quantified under ISO 14067 or GB/T 24067, has become hard currency in exports, public tendering and brand supply chains. Yet many companies are baffled the first time they meet the combination of "submit documents, define boundaries, third-party verification/validation, issue a statement."

This article breaks the complete process down step by step — what you submit at each stage, who reviews it, and where things tend to get stuck.

01 Preparing Before Verification: Purpose, Standard and Boundary

Before any document is submitted, three things need to be settled. Getting them right at the start is what keeps the rest of the process from being reworked.

02 The Full Process: From Submitting Documents to Issuing a Verification Statement

The process runs in six steps, from the first application to the final statement. Each step has a defined input, a defined reviewer and a characteristic failure point — knowing them in advance is what keeps a project on schedule.

STEP 1 · Submit the verification application and basic documents

The company submits basic documents to the verification body, including product information, process descriptions and its business license. On this basis, the body assesses the product scope, data availability and feasibility, and confirms whether it will accept the engagement.

STEP 2 · Contracting and planning

The parties agree on the functional unit, system boundary, cut-off criteria and accounting standard (commonly ISO 14067:2018; GB/T 24067-2024, published and implemented on 23 August 2024; and PAS 2050, gradually superseded by ISO 14067), and draw up a work plan with milestones. If the boundary is drawn incorrectly, the results will not be comparable.

STEP 3 · Data collection and calculation

Activity data is collected for each life-cycle stage (energy, materials, transport, waste treatment), appropriate emission factors are selected, and the product's greenhouse gas emissions are calculated. Upstream supply chain data (Scope 3) is often the hardest part to pin down.

STEP 4 · Prepare the carbon footprint report

A product carbon footprint report is produced, containing the system boundary diagram, activity data tables, sources of emission factors, and key assumptions and limitations. This serves as the input for third-party verification.

STEP 5 · Third-party verification/validation

The verification body reviews the report and the supporting data, usually including a document review and, where necessary, a site visit, to confirm that the calculation complies with the chosen standard and that the data is authentic and complete. This step determines whether the results will be accepted by customers and regulators.

STEP 6 · Issue the verification statement

Once verification/validation is passed, the body issues a product carbon footprint verification statement. Where carbon labelling or EPD rules also apply, the corresponding mark or declaration can be obtained as a further step. The validity period and ongoing surveillance requirements of any mark or declaration are subject to the specific scheme rules.

03 Four Pitfalls Companies Often Fall Into

• Unclear boundary: If the system boundary is drawn incorrectly or the cut-off criteria are applied arbitrarily, the resulting figures cannot be compared with those of the customer or peers, and are easily rejected during verification.
• Data based on estimates: Replacing measured data with industry averages or default values, or using emission factors of unknown origin, creates a high verification risk.
• Choosing the wrong standard: Different customers and markets recognise different standards (ISO 14067, PAS 2050, the GHG Protocol Product Standard, and others). Choosing the wrong one means the work is wasted.
• Neglecting the supply chain: When upstream raw materials carry a high embedded carbon burden but the data cannot be obtained, the footprint is incomplete, which undermines downstream customer acceptance.

04 How Companies Should Prepare: Four Moves

Most of the difficulty in a carbon footprint project is decided before the verifier arrives. Four moves — made early — cover the ground that companies most often leave until too late.

Point 1 · Define the purpose first

Export, tendering, brand endorsement or internal benchmarking? The purpose determines which standard you choose and how deep you go, so you do not head in the wrong direction from the outset.

Point 2 · Build a data baseline

Collect energy, material and transport ledgers first, and replace estimates with measured data wherever possible. This is the foundation for shortening the timeline and reducing verification risk.

Point 3 · Choose the right standard and the right body

Confirm in advance which standards your customer or target market recognises, then select the matching accounting standard and a qualified third-party body, so the results can actually be used.

Point 4 · Start early and keep going

A carbon footprint is not a one-off exercise: standards, boundaries and data all evolve. Building it into your routine is far easier than making a last-minute scramble.

05 CIRS Testing Product Carbon Footprint Centre

The CIRS Testing Product Carbon Footprint Centre provides product carbon footprint verification/validation services, covering everything from quantification to the verification statement, and can connect to subsequent assessments such as carbon labelling and EPD.

About CIRS Testing

CIRS Testing is a professional third-party testing organisation providing one-stop compliance solutions for chemical and product regulations worldwide. With an extensive service network, experienced technical teams and localised laboratories, CIRS Testing delivers a comprehensive range of services covering green compliance and chemical risk management, testing and certification, consulting and training.

Our service portfolio covers major regulatory frameworks including RoHS, REACH, POPs, PFAS and food contact materials (FCM), as well as sustainability services such as product carbon footprint verification and CBAM support, helping companies meet the latest requirements and mitigate trade risks on the road to sustainable development.

Note: This article is for informational purposes only and does not constitute legal advice. Standards referenced: ISO 14067:2018; GB/T 24067-2024; PAS 2050.