- 1LCA is the method; EPD is the published format verified under ISO 14025.
- 2FDES covers construction materials; PEP covers equipment that is connected.
- 3EN 15804+A2 has been mandatory since 2022 for every new or renewed declaration.
- 4Independent third-party verification: without it, the declaration is not accepted.
From the installed product to the RE2020 Ic Construction calculation
These acronyms are more than synonyms. They describe a path: the method (LCA) generates a published format (EPD), which France adapts into two declarations (FDES for materials, PEP for equipment), centralised in a database (INIES) feeding the regulatory calculation (Ic Construction).
Concrete, insulation, heat pump, light fitting: any product that goes into the building.
Life cycle assessment · ISO 14040/14044. The science that measures impacts.
Environmental Product Declaration · ISO 14025 + EN 15804+A2. Publishes verified results.
French EPD for construction products (NF EN 15804/CN).
French EPD for electrical, electronic and HVAC equipment.
All FDES and PEP centralised (6,500+ declarations). The only accepted source.
Carbon indicator in the RE2020 calculation. Determines the building permit.
Concrete, insulation, heat pump, light fitting: any product that goes into the building.
Life cycle assessment · ISO 14040/14044. The science that measures impacts.
Environmental Product Declaration · ISO 14025 + EN 15804+A2. Publishes verified results.
French EPD for construction products (NF EN 15804/CN).
French EPD for electrical, electronic and HVAC equipment.
All FDES and PEP centralised (6,500+ declarations). The only accepted source.
Carbon indicator in the RE2020 calculation. Determines the building permit.
1The four acronyms every RE2020 project eventually encounters
Since 1 January 2022, RE2020 has required project owners to declare a building’s carbon impact over its complete life cycle using two indicators: Ic Construction (emissions from installed products and equipment) and Ic Énergie (emissions from consumption during use). The first relies exclusively on product data submitted to the national INIES database. Without INIES data, there is no calculation.
An engineering consultancy receiving tender documentation and required to deliver a RE2020 calculation by a deadline quickly discovers two things. First, each work package has its own declarations: concrete and insulation use FDES, while light fittings and heat pumps use PEP. Second, some products have no declaration at all, and the calculation then switches to default environmental data (DED), which are penalising by design. Understanding who produces what, in which format and under which standard is more than a methodological luxury: it is essential to avoid delivering an artificially worsened Ic Construction score.
The common foundation of all these declarations is LCA, the scientific method that models a product’s impacts throughout its life cycle. That is where we begin.
2LCA: the scientific method underpinning every declaration
Life cycle assessment is defined by the international standards ISO 14040 (principles and framework) and ISO 14044 (requirements and guidelines). It has existed since the 90s and extends beyond buildings: LCAs are carried out for yoghurts, smartphones and TGV journeys. Its principle is always the same: reconstruct every material and energy flow entering and leaving the system under study, from raw material extraction to end of life, and translate these flows into quantified environmental impacts.
The four stages that structure every LCA
Standardised since the 90s, these four stages apply to both a m² of insulation and a fleet of smartphones. Skipping one produces a study that cannot be defended.
Four stages structure every LCA: goal and scope definition (which fixes the boundaries and functional unit), life cycle inventory (collection reaching back to suppliers), impact assessment (applying characterisation factors) and interpretation (identifying hotspots and uncertainties). In buildings, the functional unit is always expressed both as a product quantity (1 m² of insulation, 1 m³ of concrete) and over a reference service life (typically 50 years for the structure, 25 to 30 years for equipment). This dual reference is non-negotiable: without it, two materials cannot be compared.
The 5 cradle-to-grave phases
A construction product's LCA comprises 17 modules grouped into 5 main phases. RE2020 draws on the whole, with a strong focus on A1-A3 (production) and A4-A5 (construction site).
3EPDs: the international environmental declaration format
An Environmental Product Declaration (EPD) is what specialists call a Type III environmental declaration, defined by ISO 14025. In plain terms, an EPD is the standardised format that takes LCA results, presents them under common rules, has them verified by an independent third party and publishes them so that two competing products can be compared without cheating.
Why an EPD rests on two layers of standards
Without an applicable PCR, two competing EPDs cannot be compared. EN 15804+A2 is the PCR setting the rules for the building sector.
Two layers of rules are combined to produce a valid EPD. The top layer, ISO 14025, sets out general principles. The layer below, the Product Category Rules (PCR), specifies calculation parameters for each product family: functional unit, reference service life, default scenarios and indicators to publish. Without an applicable PCR, an EPD comparable with a competitor’s cannot be produced.
In buildings, the reference PCR is EN 15804. Its +A2 version, published in October 2019, transformed the landscape. It requires the PEF (Product Environmental Footprint) method with its 16 environmental impact categories (compared with 7 in version A1), plus a series of resource, waste and output flow indicators: in total, more than thirty quantities to publish for each declaration. It also introduces a single GWP (Global Warming Potential) calculation broken down into three contributions (fossil, biogenic and land use change) and harmonised end-of-life treatment through the well-known module D.
An EPD is not a label. It awards no score, does not rank products and does not say whether a product is "good" or "bad". It publishes raw figures, weighted by a defined functional unit, and leaves comparison to the specifier.
4FDES: the French version for construction products
A Fiche de Déclaration Environnementale et Sanitaire is the French EPD for a construction product. Technically, it is an EPD complying with EN 15804+A2 supplemented by the national complement NF EN 15804/CN, which adds French requirements: additional health indicators (VOCs, formaldehyde), calculation rules specific to certain work packages and mandatory submission to INIES. The national complement CN was published in late October 2022, and EN 15804+A2 became the exclusive framework for every new FDES from 1 November 2022. FDES written under version A1 before that date were removed from INIES on 1 July 2026: since that date, only FDES under EN 15804+A2 are valid in a regulatory RE2020 calculation. Archiving, originally scheduled for 1 January 2026, had been postponed by six months by a decision of the INIES steering committee in agreement with the DHUP (December 2025); that period has now expired. An A1 declaration still in a file must be replaced by its A2 version.
The national environmental data database, behind the scenes
Three organisations share responsibility for INIES. Knowing who to contact when a declaration is missing or a submission is blocked saves weeks.
What distinguishes an FDES from a generic EPD is less the figures themselves than the surrounding regulatory framework. Since 1 July 2017, every FDES published in France must be verified by an independent third party accredited by the INIES/AFNOR verification programme or an equivalent body (Order of 31 August 2015). Self-declared FDES, common before that date, are no longer acceptable for a regulatory calculation. Since the RE2020 Order of 4 August 2021, only FDES verified and submitted to INIES may be used in the Ic Construction calculation.
INIES now centralises more than 6,500 environmental datasets (FDES and PEP combined, a milestone passed in July 2025), covering most building work packages: structural works, insulation, windows and doors, finishes, plasterwork, roofing and technical equipment. The system has collective governance: Alliance HQE-GBC France leads and owns it, AIMCC (Association des Industries de Produits de Construction) chairs the Inter-Database Technical Committee and CSTB handles day-to-day technical administration. The database is free and openly accessible, and it is the authoritative reference in an inspection, rather than the engineering consultancy’s software calculation engine.
5PEPs: the electrical, electronic and HVAC equipment branch
Construction products cover only part of a building. The other half is equipment: heat pumps, mechanical ventilation, light fittings, boilers, lifts, electrical panels and air conditioning. For this family, the reference format is PEP, Profil Environnemental Produit, rather than FDES.
FDES for what is built in, PEP for what is connected
A simple rule to place each building product in the right declaration family, and therefore the right database.
- Concrete, mortar, aggregates
- Mineral wool, bio-based insulation
- Aluminium, timber and PVC windows and doors
- Plasterboard, partitions
- Floor coverings, paints
- Roofing, waterproofing
- Heat pumps, air conditioners
- Single-flow and dual-flow mechanical ventilation
- LED light fittings, ballasts
- Boilers, burners
- Lifts, goods lifts
- Electrical panels and wiring
PEP was created and is managed by the PEP ecopassport association, a sector programme launched in 2010 by the electrical engineering and climate engineering trade federations (Gimélec, IGNES, Uniclima, Profluid, AFISB). It is the reference PCR for equipment; it uses EN 15804+A2 as a common foundation but adds sector-specific rules: use scenarios incorporating electricity consumption, refrigerant management and end-of-life treatment specific to WEEE (waste electrical and electronic equipment).
In format, a PEP resembles an FDES: the same A to D modules, the same functional unit logic relative to reference service life and the same PEF and health indicators. In terms of databases, PEPs first reside in the PEP ecopassport database, then are published in INIES through an exchange procedure between the two databases. For the engineering consultancy carrying out a RE2020 calculation, the experience is seamless: PEP data appear in its software just like FDES data. However, the two databases are legally distinct, and the PEP ecopassport database remains the reference source in case of doubt.
Third-party verification has been mandatory since the programme began. A PEP published today is therefore, in practice, more reliable on average than a ten-year-old FDES that has not been updated.
6Other formats: DED, MDEGD and foreign EPDs
Three other data types can appear in a RE2020 calculation. Knowing them avoids unpleasant surprises during an inspection.
DED (Données Environnementales par Défaut) are generic values calculated by the ministry and published in INIES when a product family has no usable FDES or PEP. They allow a regulatory calculation to be completed but include an increase of at least 30% relative to verified data, mechanically worsening Ic Construction. The DED procedure is governed by an updated ministerial framework (V5, May 2023), and declarations are available on mdegd.dimn-cstb.fr. The acronym MDEGD (Module de Données Environnementales Génériques par Défaut) remains the former name still visible in some tools.
Foreign EPDs submitted to other European databases (IBU in Germany, EPD International, ECO Platform) are not directly usable in a RE2020 calculation. To incorporate them into INIES, the manufacturer must have its declaration verified under the French protocol and submit it as an FDES or PEP, which can take an additional 3 to 6 months. Plan ahead for projects sourcing imported materials.
Finally, configurable FDES (or "parameterised" FDES) are a recent variant of collective FDES: a manufacturer publishes one declaration that adjusts to the actual order (thickness, finish, options). More precise than a standard collective declaration, they avoid requiring a separate individual FDES for every product reference. They are gaining ground in highly variable work packages (windows and doors, insulation).
7The actual differences, in a table
The four terms share the same methodological family, but have different roles. Summarising their position in the ecosystem helps prevent confusion.
EPD, FDES, PEP: where the actual differences lie
Six dimensions are enough to place any declaration in any building project.
LCA = the scientific calculation method (ISO 14040/14044). It comes before everything else. Every EPD, FDES or PEP comes from an LCA; the reverse is not true.
EPD = the standardised and verified publication format for an LCA (ISO 14025 + EN 15804+A2). The generic international term. An FDES is a French EPD. A PEP is a specialised EPD.
FDES = a French EPD for a construction product (concrete, insulation, windows and doors, finishes), submitted to INIES and subject to EN 15804+A2 + the national complement CN.
PEP = a French EPD for electrical, electronic or HVAC equipment (heat pump, light fitting, mechanical ventilation, boiler, lift), submitted to the PEP ecopassport database and published in INIES through the database exchange procedure.
The three formats (EPD, FDES, PEP) now share the same technical backbone through EN 15804+A2: the same PEF impact categories, A1 to D modules and functional unit relative to service life. What separates them is the product scope they cover and the governance that validates them, rather than the method.
A manufacturer does not choose between EPD and FDES. It publishes an FDES, and that FDES is, by definition, an EPD. The four terms are four levels of the same methodological stack, rather than alternatives.
8Reading a declaration and using it in a RE2020 calculation
An FDES or PEP declaration is between 30 and 80 pages long. At first glance, it is dense. In reality, it is always structured in the same order, and a project manager who knows where to look can extract useful information in less than five minutes.
Read an FDES in 5 minutes
The five areas an engineering consultancy examines to assess an FDES, and what it looks for in practice for RE2020 Ic Construction.
Product name, manufacturer, commercial reference, INIES FDES number, version (A1/A2), expiry date.
The calculation’s reference unit (1 m² of slab, 1 linear metre of windows and doors, etc.) and the product’s reference service life.
Product contributions at each stage: production (A1-A3), transport & site (A4-A5), use (B1-B7), end of life (C1-C4), benefits beyond (D).
The 16 PEF impact categories (climate change, water, acidification, etc.) + resource and waste flows.
Transport, installation and end-of-life assumptions, and type of verification (individual third-party or collective).
Product identification. At the start: commercial designation, manufacturer, the EN 15804 version applied (A1 or A2, which changes everything), submission date and validity period (generally 5 years). If the declaration predates November 2022 and has not yet been updated to A2, it can no longer be used in a RE2020 calculation: the last A1 declarations were removed from INIES on 1 July 2026.
The functional unit and reference service life. A critical section. An insulation example: "1 m² of insulation installed in a wall with thermal resistance R = 5 m².K/W, over a service life of 50 years". Two products cannot be compared without checking that their functional units match.
Modules A1 to D. The core of the declaration. A1-A3 cover production (extraction, upstream transport, manufacturing), A4-A5 construction (downstream transport, on-site installation), B1-B7 use (maintenance, repair, replacement, water and energy consumption during operation) and C1-C4 end of life (demolition, transport, treatment, disposal). Module D aggregates benefits and loads beyond the system (recycling, reuse, energy recovery) and is declared separately because it is not added to modules A, B and C in the regulatory calculation.
Indicators. The 16 PEF impact categories (total climate change and its three sub-contributions, acidification, freshwater, marine and terrestrial eutrophication, ozone layer depletion, photochemical ozone formation, fine particles, ionising radiation, ecotoxicity, carcinogenic and non-carcinogenic human toxicity, depletion of fossil, mineral and water resources), plus indicators of resources used, waste produced and output flows. For RE2020, only GWP (total climate change, kg CO₂ equivalent) is used in the Ic Construction calculation.
Default scenarios. For modules the manufacturer does not control (mostly B and C), the declaration specifies a default scenario prescribed by the PCR. This surprises engineering consultancies discovering the system: the declaration applies a standardised scenario, rather than measuring the actual end of life.
Once the declaration has been read, use in RE2020 software (Pléiades, Cypebat, Lesosai, Archiwizard, etc.) involves automatic import from INIES: values no longer need to be entered manually. The engineering consultancy selects the product in the database; the software automatically weights it by the installed quantity and the building’s reference service life (50 years for Ic Construction), and aggregates the result at building level.
An FDES is 60 pages long, but five sections are enough to use it. An engineering consultancy that can read a declaration in less than five minutes saves several days on the project.
9Key takeaways
The four acronyms are four parts of the same system, rather than competing objects. Understanding them together saves hours on projects and avoids scoping errors that cost an entire calculation.
Three angles for mastering environmental declarations in the building sector
This article is part of a series of three publications covering FDES from three complementary angles: understanding the ecosystem, choosing the declaration on the manufacturer side, and operational use on the engineering consultancy side.
FDES, EPD, PEP: choosing and publishing the right declaration for your product
The supply-side decision-maker: individual vs collective, cost, lead time, ROI on a differentiating product.
Reading and using an FDES in an RE2020 calculation
The operational user guide: 5 critical sections + 3 grey areas for RE2020 engineering consultancies.
- LCA is the method; EPD is the format. ISO 14040/14044 define how a product’s impacts are calculated; ISO 14025 defines how these results are published in a verifiable, comparable way. A manufacturer carrying out "just an LCA" has nothing to submit to INIES.
- FDES cover construction products; PEPs cover equipment. The boundary is clear: anything anchored, insulated, bonded or built in uses an FDES; anything connected, controlled or consuming energy in use uses a PEP. INIES organisation reflects this division.
- EN 15804+A2 aligned the three formats with the same PEF impact categories, A to D modules and calculation method. Since 1 November 2022, every new or renewed declaration must comply with A2, and the last A1 declarations were removed from INIES on 1 July 2026: they can no longer be used in a regulatory calculation.
- Third-party verification is mandatory since 1 July 2017 for FDES and from the outset for PEPs. Without verification, a declaration cannot enter INIES, and without INIES it cannot enter a RE2020 calculation.
- DED penalise Ic Construction through a regulatory increase of at least 30% relative to specific verified data. For major building work packages (structural works, insulation, windows and doors), accepting DED means accepting a mechanically worsened project RE2020 score.
Design teams that invest 2 to 3 days upfront in properly mapping available declarations, checking their version and anticipating grey areas then gain weeks during tender documentation and detailed design. This is a scoping effort rather than production work: it is done once and pays off on every project. So do it properly, and early!
