Made in a similar way
The product is made in a similar way to the one in the original EPD.
An EPD owned by a trader or distributor — built on the manufacturer's existing third-party verified EPD, for a product sold under the trader's own brand.
What it is
A duplicate EPD is owned by a trader or distributor instead of the original manufacturer. They sell the product under their own brand or name but do not change how it is made or what it is made from. Because the product is unchanged, its environmental impacts are basically similar to the original manufacturer's EPD — especially across the A1–A3 product stage.
Prerequisite
The duplicate must be based on an existing EPD that has already been verified by an independent third party.
Also known as: a like-product EPD, a private label EPD, or an EPD by trader.
EN 15804 modules
A1
Raw materials
A2
Transport
A3
Manufacturing
A4
Distribution
A5
Installation
B1–B7
Use stage
C1–C4
End of life
D
Beyond
The product-stage results (A1–A3) carry over unchanged from the manufacturer's verified EPD. Only A4 — the transport to the trader's warehouse and on to the customer or final market — is recalculated for the new distribution route.
Eligibility · all three must hold
The product is made in a similar way to the one in the original EPD.
It is made with similar materials to the original product.
It is used for the same purpose as the original product.
Module A4 · transport
Manufacturer
Trader's warehouse
Customer / market
Both legs — manufacturer → warehouse and warehouse → customer or final market — are included and covered under Module A4.
The trader must get permission from the original manufacturer to use their EPD data.
The duplicate EPD must be verified by an independent third party.
The process · six steps
Start from a verified EPD
Identify the existing third-party verified EPD for the same product.
Confirm it's unchanged
Same making, similar materials, same purpose — all three.
Get manufacturer permission
Written permission to use the original EPD data.
Recalculate Module A4
Add the trader's transport & distribution legs.
Independent verification
A third party verifies the duplicate EPD.
Publish under the brand
Register and publish in the trader's own name.
Contact the program operator team for guidance on Annex F and whether it applies to your product.