- 1Four formats to choose from: international EPD, FDES for construction products, PEP for equipment, stand-alone LCA.
- 2A verified individual FDES costs €12,000 to €19,000 excl. VAT and takes 6 to 9 months to produce.
- 3A collective FDES from a trade association costs a few thousand euros but worsens your RE2020 score.
- 4Outside the scope, default values apply (DED, default environmental data), with an automatic +30% penalty.
1Every FDES and PEP is an EPD, but not every EPD can be used directly under RE2020
The four acronyms nest inside one another. LCA (life cycle assessment) is the scientific method, and it stops at measurement. EPD (Environmental Product Declaration) is the published format, verified and comparable under ISO 14025. To be used in a calculation under RE2020, France's environmental regulation for new buildings, an EPD must take the form of an FDES (Environmental and Health Declaration Sheet) for construction products or a PEP (Product Environmental Profile) for plugged-in equipment, registered in INIES, the French national database. Every FDES is by definition a valid EPD. The reverse does not hold: a German IBU EPD or an ECO Platform EPD cannot be used directly in an Ic Construction calculation (Ic Construction is the RE2020 indicator of embodied carbon).
From the installed product to the RE2020 Ic Construction calculation
These acronyms are not mere synonyms. They trace a path: the method (LCA) generates a published format (EPD), which France breaks down into two sheets (FDES for materials, PEP for equipment), centralised in a database (INIES) that feeds 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 the verified results.
French EPD for construction products (NF EN 15804/CN).
French EPD for electrical, electronic and HVAC equipment.
All FDES and PEP sheets centralised (6,500+ sheets). The only accepted source.
Carbon indicator of the RE2020 calculation. The building permit depends on it.
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 the verified results.
French EPD for construction products (NF EN 15804/CN).
French EPD for electrical, electronic and HVAC equipment.
All FDES and PEP sheets centralised (6,500+ sheets). The only accepted source.
Carbon indicator of the RE2020 calculation. The building permit depends on it.
For a manufacturer, the first question is therefore not which of the four sheets to publish but which one its customers will accept, in France under RE2020 as elsewhere in Europe. The answer depends on two things only: the physical nature of your product (built in or plugged in) and the market you are targeting (France under RE2020, or Europe in general).
The overview in this section sets out the full path, from the acronyms to the parties in charge.
2FDES or PEP: the line falls between built-in products and plugged-in equipment
FDES covers everything that is anchored, insulated, bonded or built into the building: concrete and mortar, mineral and bio-based insulation, windows and doors (aluminium, timber, PVC), plasterboard and partitions, floor coverings and paints, waterproofing and roofing. In other words, the structural work and the passive finishing work.
FDES for what is built in, PEP for what is plugged in
A simple rule for placing each building product in the right family of declaration, and therefore in 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 (VMC)
- LED luminaires, ballasts
- Boilers, burners
- Lifts, goods hoists
- Electrical distribution boards and wiring
PEP covers everything that is plugged in and controlled and that consumes energy in use: heat pumps, single-flow and dual-flow mechanical ventilation (VMC), LED luminaires and ballasts, boilers, lifts, electrical distribution boards and wiring, air conditioning. What sets a PEP product apart is that it consumes energy in modules B6-B7, which brings in use-phase data that an FDES does not have to model.
As a rule of thumb, a product with a power cable or a control panel is a PEP product, and one that takes its final form on site (poured concrete, installed insulation, windows and doors set in place) is an FDES product. There are grey areas (an electric radiator, a motorised blind, built-in home automation), but they are a minority, and when in doubt the product category rules (PCR) for the sector decide.
3INIES, PEP ecopassport and ECO Platform: only INIES data is accepted as it stands
Whether a sheet is accepted in a RE2020 calculation depends on the database it is registered in. Three databases coexist, each with its own logic.
The national database of environmental data, behind the scenes
Three organisations share responsibility for INIES. Knowing who to talk to when a sheet is missing or a submission is stuck saves weeks.
INIES is the French national database and, for a manufacturer, the one to target. It holds more than 6,500 sheets (a threshold crossed in July 2025), covering most of the work packages of a building, and it is the only database whose data is accepted as it stands in RE2020 calculation software (Pléiades, Cypebat, Lesosai, Archiwizard). It is led by the Alliance HQE-GBC France (the French sustainable building association); the AIMCC (the trade association of construction product manufacturers) holds the technical chair and the CSTB (the French Scientific and Technical Centre for Building) administers it day to day.
PEP ecopassport is the sector database dedicated to equipment, run by the association of the same name (Gimélec, Ignes, Uniclima, AFAQ). Each PEP is then transferred to INIES under an exchange agreement, so an equipment manufacturer deals with a single entry point (PEP ecopassport), not two.
ECO Platform is the European association of national EPD programmes (IBU in Germany, EPD International, MRPI in the Netherlands). An ECO Platform EPD is valid on the European market, but to be used in a RE2020 calculation it must go through an additional registration in INIES. The CSTB manages the procedure, which takes a few weeks.
4Four questions to decide which declaration suits your product
Four questions guide an R&D or product marketing team through the choice. The format of the sheet depends on the product, the market and the volume.
Which environmental declaration for your product?
Three questions to point a manufacturer to the right format (FDES, PEP or EPD), based on its product type, commercial intent and target market. Indicative only: it does not replace a project scoping exercise.
What is the physical nature of your product?
The declaration format depends first on how the product is installed: set in place, plugged in, or outside the scope of the construction industry.
5Individual or collective FDES: cost, lead time and effect on your score
The two formats differ in cost by a factor of 5, and the choice affects the score of your product in RE2020 calculations.
How much an FDES costs, and what score you get
Three formats for entering INIES. The entry cost varies by a factor of 5, and the decision is about more than budget: it also involves a trade-off on the final score that will appear in your customers' Ic Construction calculation.
Individual FDES
Your data, your processes, your actual score.
Collective FDES
Published by your trade association.
Configurable FDES
A declaration that can be parameterised to suit the order.
Individual FDES
Your data, your processes, your actual score.
Collective FDES
Published by your trade association.
Configurable FDES
A declaration that can be parameterised to suit the order.
An individual FDES costs between €10,000 and €15,000 for drafting by an accredited body (CSTB, Bureau Veritas and others) and €2,000 to €4,000 for the mandatory third-party verification. The typical lead time is 6 to 9 months from launch to publication, because LCA data has to be collected from your suppliers (modules A1-A2). It suits a manufacturer that wants its sheet to reflect its own performance and to benefit from optimised sourcing or low-carbon processes.
A collective FDES is published by a trade association (UNICEM for aggregates, UNPMF for insulation and so on) and covers a generic product type. It is either free or charged at a few thousand euros when you join. But it includes a conservative safety margin, typically +10% to +20% on the indicators, so as to cover all members. As a result, your product inherits the weighted average score, even if it performs better than the association's average.
For products that stand out from the market, the economics are reversed. If your low-carbon concrete performs 20% better than the generic one, the individual FDES pays for itself on the first public contract where that difference gets you over an Ic Construction threshold.
A configurable FDES is a recent variant: the manufacturer publishes a single sheet, parameterised for each order (thickness, finish, length). It is particularly useful for windows and doors and for coverings, where each product reference in the catalogue does not justify a dedicated FDES. Its cost sits between that of an individual and a collective FDES.
6Regulatory timeline: verification is mandatory and A1 sheets have been withdrawn
The milestones explain the time frames manufacturers have to work to. The body of standards has been built up over twenty years and is still evolving.
The milestones that shaped the FDES market
The body of standards was built up over two decades. For a manufacturer, two dates matter: the publication of A2 (which sets the current format) and the end of the transition on 31 December 2025 (which forces the renewal of the catalogue).
2006: ISO 14025 sets the principles of type III environmental declarations, the foundation of every EPD. 2012: EN 15804 lays down the PCR for the construction sector. 2019: EN 15804+A2 rewrites the standard. It brings in the European Product Environmental Footprint (PEF) method with its 16 impact categories, and breaks global warming potential (GWP) down into fossil, biogenic and land use components. 4 August 2021: the RE2020 ministerial order makes third-party verification mandatory for eligible FDES, which ends self-declared sheets.
2026: A1-format sheets are withdrawn from the INIES database, on 1 January 2026 for those verified in 2020 and on 1 July 2026 for those verified in 2021 and 2022. Only A2 sheets remain available for a RE2020 calculation.
Looking ahead to 2027-2030: the new European Construction Products Regulation (Regulation (EU) 2024/3110) progressively makes the declaration of product environmental indicators mandatory, starting with climate impact. And upstream scope reporting under the CSRD (Corporate Sustainability Reporting Directive, ESRS E1) makes the availability of FDES data a selling point with project owners that report their product footprint.
7EPD, FDES and PEP side by side: cost, RE2020 eligibility, governance and standard
The table below compares seven dimensions: cost, RE2020 eligibility, governance, standard and format.
EPD, FDES, PEP: where the real differences lie
Six dimensions are enough to place any sheet on any building project.
8Key takeaways
The four acronyms are four layers of one stack rather than four competing options for a manufacturer, and only the last two (FDES and PEP) can be used in France. The remaining choice is between an individual and a collective sheet.
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 sheet on the manufacturer side, and operational use on the engineering consultancy side.
EPD, FDES, PEP, LCA: understanding environmental declarations
The complete overview of the 4 acronyms that structure environmental data for buildings.
Reading and using an FDES in an RE2020 calculation
The operational user guide: 5 critical sections + 3 grey areas for RE2020 engineering consultancies.
A manufacturer that publishes a collective FDES "by default" to avoid the cost of an individual one ends up inheriting its competitors' average score, plus the 10% to 20% safety margin applied by the trade association.
Three actions to decide on this year: (1) map your direct competitors' existing sheets in INIES; (2) check the validity of your current sheets (A1 versus A2, 5 years' validity); (3) work out the return on investment of an individual FDES on the tenders where the Ic Construction criterion is a differentiator.
