--- title: "FDES and PEP:\nhow do you choose an approved verifier?" description: "Who can verify an FDES or a PEP? A verifier approved by INIES or PEP ecopassport, independent of the manufacturer. Public list, real lead times, registration fees." canonical: https://projetcelsius.com/en/blog/fdes-pep-choose-accredited-verifier/ author: "Sébastien Pierfederici" datePublished: 2026-10-15 dateModified: 2026-10-17 language: en translationOf: https://projetcelsius.com/blog/fdes-pep-choisir-verificateur-habilite/ --- # FDES and PEP: how do you choose an approved verifier? **Author**: Sébastien Pierfederici **Published**: 2026-10-15 **Updated**: 2026-10-17 **Section**: Practical guide **Canonical URL**: https://projetcelsius.com/en/blog/fdes-pep-choose-accredited-verifier/ **French original**: https://projetcelsius.com/blog/fdes-pep-choisir-verificateur-habilite/ **Source**: Projet Celsius (https://projetcelsius.com/en/), a climate strategy consultancy of engineers and PhDs based in Paris and Marseille. > Only a **verifier approved by the programme** of the declaration can verify it: INIES, the French construction products database and programme, for an [FDES](https://projetcelsius.com/en/blog/epd-fdes-pep-lca-differences/), and PEP ecopassport for a PEP. The verifier must **neither have taken part in the declaration** nor have had any link with the manufacturer in the last 3 years. Verification has been **mandatory in France since 1 July 2017**. INIES listed **58 verifiers** in July 2026, and 5 published files show verification times from 5 weeks to 11 months. ## Key takeaways - **Only a verifier approved by the programme** can sign the verification attestation. - **The verifier and their organisation** must not have contributed to the declaration. - **Book the verifier when the study is launched**: the wait can last several months. - **No public price list**: compare several quotes on the same verification scope. An **FDES** (*fiche de déclaration environnementale et sanitaire*, the French format of environmental product declaration, or EPD, for construction products) states the impact of a construction product over its whole [life cycle](https://projetcelsius.com/en/blog/lca-vs-carbon-footprint/). A **PEP** (*profil environnemental produit*, Product Environmental Profile) does the same for electrical or HVAC (heating, ventilation and air conditioning) equipment. Engineering consultancies use both in the [RE2020 calculation](https://projetcelsius.com/en/blog/how-to-read-fdes-re2020/) (RE2020 is France's environmental regulation for new buildings), drawing on the INIES database, the French national database of environmental declarations, which held **5,660 and 1,888** of them respectively on 16 October 2026. No declaration enters this database **without the attestation** of an approved verifier. Choosing that person takes only a few criteria, but it sets the timetable. Attestations published by manufacturers show **5 weeks to 11 months** between the file being handed to the verifier and the verification date written on the attestation. ## What is an approved verifier? An approved verifier is **an individual** whom a declaration programme has recognised, after assessment, as able to verify the declarations it registers. **INIES** does this for FDES, and **PEP ecopassport**, the programme that registers PEPs, does it for PEPs. The 2 programmes are under agreement with the French State, and approval by one is **not valid for the other**. ### How does someone become a verifier? At INIES, the candidate sits **an examination** held at least once a year: a prepared case study, then a discussion with a jury. They must have a command of French, have carried out **at least 2 FDES** for different product families in the last 2 years, and know the NF EN 15804 standard (the French edition of the European standard for construction product EPDs). The programme's steering committee grants the approval. PEP ecopassport reviews a file, then holds **an oral interview** in front of a panel of the programme's designated referents. The approval is valid for **3 years** and is renewed only with at least 2 verifications carried out over the period and an annual activity report. ### What the verifier hands over Verification produces **2 documents**. The **attestation**, dated and signed, carries the verifier's declaration on honour of independence. The **verification report** lists the deviations judged not significant and remains confidential: INIES receives it but does not publish it. ### What the verifier checks The [ministerial order of 14 December 2021](https://aida.ineris.fr/reglementation/arrete-141221-relatif-a-verification-tierce-partie-independante-declarations) (an *arrêté*, in French) sets what the verification covers. The verifier reviews the study behind the declaration, a [product LCA](https://projetcelsius.com/en/blog/product-carbon-footprint-lca-pef-cfp/), across **5 groups of points**: - The **scope of the study**, meaning the system boundaries and the cut-off criterion that excludes flows judged negligible. - Data collection and selection, and their **geographical, technological and temporal representativeness** for the product sold in France. - The **scenarios** used for each stage, from transport to the building site through to end of life, and the allocation rules between co-products. - The modelling, the calculation of the indicators, then the presentation and **interpretation of the results** in the declaration itself. - Additional information, including the **health section** and comfort information specific to FDES, and the environmental messages of the declaration. ## Is verification mandatory? Yes, in France. Since **1 July 2017**, declarations for construction products, decoration products and building equipment must be verified by an **independent third party** whenever the manufacturer makes environmental claims about its product. The [HQE-GBC Alliance](https://www.hqegbc.org/wp-content/uploads/2017/07/Communique-de-presse-1er-juillet-valide.pdf), France's sustainable building association, recalled this in its press release of 3 July 2017. ### The text in force The **ministerial order of 14 December 2021**, applicable since 1 January 2022, now governs this verification. Its Article 9 **repeals the order of 31 August 2015**, which contracts and web pages still cite. Since 1 November 2022, a new FDES is calculated under **NF EN 15804+A2** and its national complement. ### The programme's own checks The programme then checks the verifiers' work. The order requires it to check each year **at least 20% of the declarations** verified the previous year, and to entrust **at least 5%** of them to another third party, which reviews the report and the data. These checks matter all the more because FDES feed the [RE2020 carbon indicator](https://projetcelsius.com/en/blog/new-building-carbon-footprint-re2020/), whose [thresholds tighten in 2028](https://projetcelsius.com/en/blog/re2020-2028-thresholds/). > **Good to know** **Verification is not a critical review.** It checks that a declaration complies with the rules of its programme, whereas a critical review assesses an LCA study under ISO 14044. How to choose who reviews a study is covered in our article on [the critical review of an LCA (in French)](https://projetcelsius.com/blog/revue-critique-acv-choisir-expert-independant/) (in French). ## How do you choose your verifier? The selection takes 3 steps: **independence** first, then whether the person is on the programme's list, and finally their answers to the questions that come before the quote. ### Independence is not negotiable The attestation contains a **declaration on honour** in 3 points, required by the 2021 order. The verifier is **not employed by the manufacturer**, declares their links of interest with it **over the last 3 years**, and did not take part in drawing up the declaration. The INIES attestation template goes further: the verifier states there that they have had **no link of interest** with the manufacturer over that period. INIES extends this requirement to [any third party that contributes](https://www.inies.fr/deposer-ma-declaration/faire-verifier-sa-declaration/) to the declaration, engineering consultancy included: the one that carried out the [product's first LCA](https://projetcelsius.com/en/blog/first-product-lca-steps-cost-mistakes/) cannot verify it. In its calls for projects, the HQE-GBC Alliance also rules out a declaration being verified by **a person from the same organisation**. The rules of ECO Platform, the European association of declaration programmes, add that the verifier **makes no recommendations**. ### The public list, and what it tells you Each programme publishes its list. The [INIES](https://www.inies.fr/wp-content/uploads/2026/05/20260717_Liste-des-verificateurs.pdf) list, updated on 17 July 2026, has **58 people**, with the end date of their approval. The [PEP ecopassport](https://pep-ecopassport.org/site/wp-content/uploads/2026/10/PEP-AP0006-ed18-FR-2026-09-10-liste-verificateurs-habilites.pdf) list has **60** as at 10 September 2026, with their working languages. INIES approves new verifiers **about twice a year**, but the pool remains narrow compared with the 5,660 FDES online, which have to be re-verified at each renewal. The programme advises signing a contract **at the start of the project**, failing which the wait can last **several months**. ### Questions to ask before the quote **5 questions** help sort candidates in a first conversation: - Does your approval cover this programme, and until what date? The public INIES or PEP ecopassport list lets you check before signing. - Has your organisation contributed to this declaration, to its LCA or to the tool that produced it? A yes rules the candidate out, even if the person did not work on it themselves. - How many declarations for this product family have you verified in recent years? An insulation material, a joinery product and a heat pump do not raise the same questions. - When can you start, and how many rounds of exchanges does the quote include? These 2 answers fix the publication date more reliably than the length of the review. - Will you work from an LCA report in English and from the calculation model? Most INIES verifiers accept English, according to the programme. 3 signals, conversely, should give you pause: - The candidate offers to **correct the calculation themselves** or to write part of the declaration, which would take them outside the role of verifier. - Their name is **missing from the programme's list**, or their approval ends before the date on which the verification is to be signed. - The quote **guarantees an online publication date**, whereas it is the programme that admits the declaration, after its own check. ## How long does a verification take, and how much does it cost? The lead time is decided **before the attestation**. Going online and registration cost little and take little time, provided the file is consistent. ### How long verification takes The attestations published by 5 manufacturers or sectors give the date the verifier received the declaration and the verification date. The gap runs from **5 weeks**, for the update of a collective FDES for wooden battens, to **11 months** for communal letterboxes. These gaps combine the verifier's diary, **the rounds of exchanges** and the manufacturer's time to make corrections. The shortest file was an update, already verified once before. ### Going online on INIES After the attestation, the manufacturer enters its FDES in the database and requests that it go online. Of the **2,633 new FDES** published between January 2025 and 16 October 2026, half went online **less than 27 days** after verification, according to the dates in the INIES database. The median is 21 days before the manufacturer's request, then 5 days for admission by INIES. The admission check rejects an incomplete file, a poorly drafted health summary, **a missing indicator** or a negative value. ### The price **No verification price list** is published by INIES, by PEP ecopassport or by the HQE-GBC Alliance: each verifier sets its own quote. The programmes do publish their registration fees, however. At INIES, an FDES costs **€220 excl. VAT**, or €190 for 20 or more, and an unlimited subscription costs **€3,200 excl. VAT per year**, under the December 2024 fee schedule, still in force. PEP ecopassport charges **€280 to €865 excl. VAT** to register a PEP depending on the manufacturer's membership, under its 2024 fee schedule, still published. The study itself is priced separately: see [how much an LCA costs](https://projetcelsius.com/en/blog/lca-cost/), how to [carry out an LCA on a small budget](https://projetcelsius.com/en/blog/lca-on-a-small-budget/) and the [funding schemes that help pay for it](https://projetcelsius.com/en/blog/climate-transition-funding-carbon-footprint-lca/). ## What should you prepare to avoid back-and-forth? A study run under a [structured eco-design process](https://projetcelsius.com/en/blog/eco-design-process-7-steps/) makes the file simpler to put together, which shortens the verification and prepares the way for going online. ### Documents to hand over The verifier must receive, **from the first submission**, the documents that carry the calculation: - The draft FDES or PEP, with its **functional unit**, the product description, the product references covered and the lifetime used. - The supporting report or the LCA report, which explains the system boundaries, the cut-off rules, the allocations and **the scenarios**. - The **production data** and its sources, with the year, the site and the version of the database used for each significant flow. - The supporting evidence for the health and comfort section of an FDES, and the **evidence of the product's fitness for use**, such as standards or technical assessments. - The **registration number** issued by the INIES interface before verification, to be entered on the declaration and on the attestation. ### A comment and its correction Because the verification report is not published, the example below is **constructed for this article**. It concerns stage A4, transport of the product to the building site, and a point that the 2021 order requires to be checked: the **geographical representativeness** of the data. > **Example constructed for this article** **Comment.** The A4 scenario uses 50 km of transport, whereas the product leaves a single factory and is sold throughout France. The distance is not justified. **Correction.** The manufacturer replaces the 50 km with the average distance of its deliveries over the year, weighted by volume, explains this in the supporting report and recalculates module A4. The verifier closes the comment. As long as a comment remains open, **the attestation waits**. A written, justified assumption in the first submission most often avoids the question. A team [trained in LCA](https://projetcelsius.com/en/blog/lca-training-courses-how-to-choose/), for example through an [LCA training course](https://projetcelsius.com/en/training/lca/), anticipates such comments better. > An FDES timeline depends less on the INIES database than on the verifier and the back-and-forth with them. ### After going online, complaints The file is still useful after publication. Anyone may report a suspected anomaly in an FDES, and [Annex H of the INIES programme rules](https://www.inies.fr/wp-content/uploads/2026/10/Reglement_programme_INIES_Annexe_H_Procedure_traitement_anomalies_2026_09_FR.pdf) (in French) then gives the manufacturer **10 working days** to reply if the anomaly is critical or major. It then has **1 month at most** to correct a critical anomaly and 3 months for a major one, and its correction **goes back through a verifier**. An anomaly is **major** when correcting it changes one of the indicators by more than 10%, and critical when that change affects the total climate change indicator. An FDES is also used to [prove an environmental claim](https://projetcelsius.com/en/blog/green-claims-what-empco-bans/), and an error left in it risks [unintentional greenwashing](https://projetcelsius.com/en/blog/greenwashing-test-3-questions/). ## What about a PEP or a foreign declaration? ### A PEP A PEP, such as that of an [air-conditioning unit](https://projetcelsius.com/en/blog/air-conditioning-environmental-impact/) or an electrical switchboard, is verified under PEP ecopassport's AP0002 procedure, which results in a signed **declaration of conformity** and a verification report. PEPs currently follow the product category rules in **edition 4**, published in September 2021, which align their indicators with those of FDES. The PEP ecopassport list distinguishes external verifiers from those who verify **in-house**, for their employer: 9 of the 60 are in this group. The programme's procedure allows it, but the 2021 order requires, for a declaration used in France, **a verifier not employed** by the manufacturer. Only **35 of the 60** state that they work in French. ### A foreign declaration A declaration published elsewhere in Europe, called an **EPD** (environmental product declaration, the international and European equivalent of the FDES), does not replace an FDES. Where it has been verified in a programme that is a member of ECO Platform, with a compliant functional unit, [INIES does not re-verify](https://www.inies.fr/en/who-are-we/our-international-action/) **modules A1 to A3**. An approved verifier checks the other modules and the health section. Recognition is not automatic. The [German IBU](https://ibu-epd.com/en/international-2/mutual-recognitions/) (Institut Bauen und Umwelt, a German EPD programme) states that its recognition with INIES has been **suspended** since the switch to A2. Each programme also sets its own requirements: the International EPD System approves only verifiers who can show 5 years of LCA practice. Our guide on [choosing between FDES, EPD and PEP](https://projetcelsius.com/en/blog/fdes-vs-epd-vs-pep/) helps decide upstream, and the one on [building eco-design](https://projetcelsius.com/en/blog/re2020-which-buildings/) shows what project owners expect. For the opposite case, when a foreign customer asks for an EPD, see [which programme and verification to choose for export](https://projetcelsius.com/en/blog/epd-verification-for-export/). For us at Projet Celsius, the first question to put to a verifier concerns **their organisation**: has it touched, closely or remotely, the study or the tool that produced the declaration? We [prepare LCAs and declarations](https://projetcelsius.com/en/services/life-cycle-assessment/) with manufacturers, and verification then falls to a person from another organisation, whom they choose. Booking that person **when the study is launched** remains the surest way to hold a publication date. The same independence rule applies to [verifying a carbon footprint assessment (in French)](https://projetcelsius.com/blog/bilan-carbone-interne-verification-tiers/) (in French) or [auditing environmental claims](https://projetcelsius.com/en/blog/empco-green-claims-audit/). ## Key takeaways - An FDES is verified by one of the 58 verifiers approved by INIES, a PEP by one of the 60 approved by PEP ecopassport. - The verifier is not employed by the manufacturer, has had no link of interest with it in the last 3 years, and their organisation has not contributed to the declaration. - Verification has been mandatory since 1 July 2017, and the order of 14 December 2021 replaced the 2015 one. - Across 5 published files, verification took from 5 weeks to 11 months. It is therefore better to book the verifier when the study is launched. - No verification price list is published, whereas registering an FDES on INIES costs from €190 to €220 excl. VAT. To understand what an FDES contains before having it verified, see our [guide to the acronyms EPD, FDES and PEP](https://projetcelsius.com/en/blog/epd-fdes-pep-lca-differences/). ## Frequently asked questions ## Frequently asked questions ### Who can verify an FDES? Only a verifier approved by the INIES programme and listed on its public list, which had 58 people on 17 July 2026. The verifier must not be employed by the manufacturer, must not have had any link of interest with it over the last 3 years and must not have taken part in the declaration. The verifier hands over a signed attestation and a verification report. ### Where can I find the list of approved INIES and PEP verifiers? Each programme publishes its own. The INIES list is on the "Faire vérifier sa déclaration" (Have your declaration verified) page of inies.fr, updated on 17 July 2026. The PEP ecopassport list, document AP0006, is on the "Devenir vérificateur" (Become a verifier) page of the programme's website, in the edition of 10 September 2026. ### Can an engineering consultancy verify an FDES it produced itself? No. The verifier must not have taken part in drawing up the declaration, and INIES extends this rule to any third party that contributed to it. The HQE-GBC Alliance also rules out a declaration being verified by a person from the organisation that produced it. The consultancy prepares the file; a verifier from another organisation verifies it. ### How long does it take to verify an FDES? For 5 FDES whose attestation is published, the gap between the verifier receiving the file and the verification date on the attestation runs from 5 weeks to 11 months. Going online on INIES follows within a few weeks: for new FDES published since January 2025, half went online less than 27 days after verification. ### How much does FDES verification cost? There is no public price list: each verifier sets its own quote according to the complexity of the product and the number of rounds of exchanges. On top come the INIES registration fees, €220 excl. VAT per FDES, or €190 for 20 or more, or a subscription of €3,200 excl. VAT per year for an unlimited number of declarations. ### How long does a verified FDES remain valid? 5 years as a general rule, according to INIES, and the end date appears on the verification attestation. A change that alters one of the indicators by more than 10% must be reported to the verifier, under NF EN 15804+A2. An FDES that has reached the end of its validity is archived automatically by the INIES database. ## Sources - INIES, [List of verifiers approved by the INIES programme](https://www.inies.fr/wp-content/uploads/2026/05/20260717_Liste-des-verificateurs.pdf) (in French), updated 17 July 2026; earlier lists since July 2023. - PEP ecopassport, [List of approved verifiers, AP0006 ed. 18](https://pep-ecopassport.org/site/wp-content/uploads/2026/10/PEP-AP0006-ed18-FR-2026-09-10-liste-verificateurs-habilites.pdf) (in French), 10 September 2026; editions 7 (2023), 8 (2024), 11 (2025) and 13 (2026). - Ministerial order of 14 December 2021 on independent third-party verification of environmental declarations, [text on AIDA (INERIS)](https://aida.ineris.fr/reglementation/arrete-141221-relatif-a-verification-tierce-partie-independante-declarations) (in French), Articles 2 to 5 and 9. - Ministerial order of 20 October 2022, [NF EN 15804+A2 for declarations](https://aida.ineris.fr/reglementation/arrete-201022-modifiant-larrete-14-decembre-2021-relatif-a-declaration) (in French). - INIES, [Faire vérifier sa déclaration](https://www.inies.fr/deposer-ma-declaration/faire-verifier-sa-declaration/) (Have your declaration verified) and [Devenir vérificateur](https://www.inies.fr/devenir-verificateur/) (Become a verifier), in French. Consulted on 16 October 2026. - INIES, [The INIES verification programme](https://www.inies.fr/contexte-reglementaire/le-programme-de-verification-inies/) and [Registering your declaration](https://www.inies.fr/deposer-ma-declaration/enregistrer-sa-declaration/), in French. Consulted on 16 October 2026. - INIES, programme rules, in French: [Annex A, pricing conditions](https://www.inies.fr/wp-content/uploads/2026/01/Reglement_programme_INIES_ANNEXE_A_Conditions_tarifaires_2025_12_FR.pdf); [Annex H, handling of suspected anomalies](https://www.inies.fr/wp-content/uploads/2026/10/Reglement_programme_INIES_Annexe_H_Procedure_traitement_anomalies_2026_09_FR.pdf), September 2026; [Annex L, admission of a declaration](https://www.inies.fr/wp-content/uploads/2021/06/Annexe-L-Procedure-admission-dune-Declaration-environnementale-Mai-2023.pdf), May 2023. - INIES, [Annual day of 28 June 2023, compilation of presentations](https://www.inies.fr/wp-content/uploads/2023/07/Journee-annuelle-INIES-du-28-juin-2023-Compilation-des-presentations.pdf) (in French). - Alliance HQE-GBC, in French: [press release of 3 July 2017 on mandatory verification](https://www.hqegbc.org/wp-content/uploads/2017/07/Communique-de-presse-1er-juillet-valide.pdf); [call for support no. 4, call for verifiers](https://www.inies.fr/wp-content/uploads/2025/05/AAA4-Projets-retenus-et-appel-a-prestataires-et-verificateurs-2.pdf), May 2025. - PEP ecopassport, in French: [verification procedure AP0002](https://pep-ecopassport.org/site/wp-content/uploads/2026/04/AP-0002-ed4-FR-2016-05-13-PEP-verification-procedure.pdf), [approval procedure AP0003](https://pep-ecopassport.org/site/wp-content/uploads/2026/08/PEP-AP0003-ed10-FR-2024-06-13-procedure-habilitation-verificateurs.pdf), [registration fees AP0009](https://pep-ecopassport.org/site/wp-content/uploads/2026/04/PEP-AP0009_ed5-FR-2023_12_08_Tarifs_enregistrement.pdf) and [product category rules, edition 4](https://pep-ecopassport.org/site/wp-content/uploads/2026/04/PCR-4-ed4-FR-2021-09-06-PCR-edition-4.pdf). - ECO Platform, [Verification Guidelines V07](https://www.eco-platform.org/files/download/Documents/2023/2_Verification%20Guidelines%20V07_final.pdf), 2023; INIES, [Our international action](https://www.inies.fr/en/who-are-we/our-international-action/). - IBU, [Mutual recognitions](https://ibu-epd.com/en/international-2/mutual-recognitions/); The International EPD System, [Individual verifier application](https://environdec.com/services/individual-verifiers-application). Consulted on 16 October 2026. - Durlumen, [FDES of anodised honeycomb ceilings](https://www.durlumen.com/fileadmin/13_Microsite_FR/FDES/26.033_FDES_durlumen.pdf) and [verification attestation](https://www.durlumen.com/fileadmin/13_Microsite_FR/FDES/26.033_Attestation_de_verification_FDES_20260450556_durlumen.pdf), in French, 6 May 2026; attestations published by RENZ, Swisspearl, Uponor and ATIBT; INIES database, verification and publication dates, consulted on 16 October 2026. - Cover photo: Fons Heijnsbroek, Oosterdokseiland building site in Amsterdam, [Wikimedia Commons](https://commons.wikimedia.org/wiki/File:Constructions_and_scaffolding_at_the_Oosterdokseiland,_Amsterdam-Centrum.jpg), CC0.