exergy
Send an enquiry →
Home  ›  Insights
Green claims

Environmental labels and declarations: Type I, II and III — how do they differ?

Author: Radosław Andrulewicz
Updated:
Environmental labels and declarations: Type I, II and III

A customer asks for your product's "environmental declaration". One buyer means an ecolabel on the pack, another a claim about recycled content, a third a 20-page report with life cycle data. These are three different documents, with different costs and different people who check them.

Label, declaration, claim: why are the names so confusing?

Environmental labels, declarations and claims: the namesISO 14020 sets the frame for all three types. Its 2022 edition changed the title: "labels and declarations" became "statements and programmes". The terms shifted, but the split into three types stayed. This is one reason why the same things now have several names.

In practice, three shortcuts help:

Four standards make up this system:

How to settle it in a conversation

When a customer, a supplier or a buying team says "we need an environmental declaration", ask for the number of the standard. ISO 14024, ISO 14021 or ISO 14025: only this tells you which document they mean, what it costs and who checks it.

Two other documents with a similar name

Documents with names similar to environmental declarationsBefore we get to the types, let us set aside two documents with a similar name that deal with something else. If you are looking for one of them, the rest of this article is not about it:

The rest of this article covers declarations as ISO standards define them: product information for the market.

Why make environmental declarations?

Why companies make environmental declarationsAn environmental declaration answers a simple question from a buyer. What does this product do to the environment, and how do I know it is true? The answer helps in four situations:

  1. consumer sales: a mark or a specific figure on the pack builds trust faster than a statement of company values;
  2. tenders and public procurement: buyers more and more often score proven results, not stated intentions;
  3. supply chain: business customers calculate their own carbon footprint and need data from suppliers, ideally in a form they can count;
  4. reporting and sustainability strategy: the same data feeds the sustainability report and the plan to cut emissions.

In each case the point is the same: transparency. A declaration turns general green statements into facts you can check. An informed buyer, whether a consumer in a shop or a buyer in a tender, gets a basis to compare greener products with the rest.

This is part of a wider change. Sustainability is moving from company strategy down to the single product, and declarations make this possible. The raw material of a product is no longer a technical detail. It becomes sales information.

One thing links all of them: a declaration must describe the real effect of the product on the environment. That means from raw materials, through production and use, to the waste at the end of the product's life. The wider the scope, the harder it is to challenge the message.

Type I: ecolabels under ISO 14024

Type I ecolabel under ISO 14024Type I is a mark awarded by an independent ecolabelling programme (ISO 14024:2018). The programme sets criteria for a whole product category. A company may use the mark only when its product meets these criteria and passes an audit.

Three things set an ecolabel apart from the other types:

  1. it is selective: only part of the products in a category meet the criteria, so the mark stands out;
  2. it has several criteria: it looks at the whole life cycle, not one feature;
  3. it needs a licence: the right to the mark ends after a time, and the criteria change every few years, so you must renew it.

The criteria do not cover a single feature. They usually cover raw materials, energy and water use, emissions, waste, packaging and how long the product lasts. The programme checks them in regular audits.

For a buyer, an ecolabel shortens the path to an informed choice. Instead of comparing products, it is enough to recognise the mark. This is also why Type I marks are protected. If no one checked the criteria, the mark would say nothing about whether the product really harms the environment less.

The best-known programmes are the EU Ecolabel, the German Blue Angel and the Nordic Swan. An ecolabel is a strong argument in consumer sales and in green public tenders, which sometimes name it directly. But it works only where criteria exist for the product group, and they do not exist for everything.

Type II: self-declared environmental claims under ISO 14021

Type II self-declared environmental claims under ISO 14021Type II is a claim that the company makes itself and on its own responsibility. It can appear on a label, a pack, in a catalogue, an advert or on a product page. It needs no certificate, but it needs evidence. The standard sets four conditions. The claim must be accurate, verifiable, relevant to the product and not misleading. The supporting documents must be available on request.

ISO 14021 also leaves no freedom in the words. It defines specific terms and how to support them. Examples are "recycled content", "recyclable", "compostable", "reusable", "reduced energy use" and "renewable energy". It also sets the rules for the Möbius loop.

In June 2026, ISO published the third edition of the standard, ISO 14021:2026, which replaced ISO 14021:2016. The main change: a single claim is no longer enough. It must be part of a written programme of claims, with criteria, a method and a named owner. Independent verification of environmental claims confirms that a claim meets the new edition.

Type II causes most damage to reputation, because no one checks it before it goes out. Vague terms such as "eco" and "environmentally friendly", and home-made marks that look like certificates, are now a legal risk, not only a reputational one. We write about this in what is greenwashing and in our guide on how to avoid greenwashing.

Type III: environmental product declarations (EPD) under ISO 14025

Type III environmental product declaration (EPD) under ISO 14025An environmental product declaration (EPD) follows a completely different logic from the first two types. It does not rate the product and does not award it a mark. It gives figures. These are the results of a life cycle assessment (LCA) under product category rules (PCR). An independent verifier checks them, and an EPD programme publishes them. ISO 14025:2006 sets out the rules. We break down the calculation behind these figures in our article on how to calculate a product carbon footprint.

A Type III declaration describes a product with a set of indicators for its whole life cycle. This runs from raw material extraction, through production and transport, to use and waste treatment. Next to the carbon footprint, you will find acidification, eutrophication, water use and primary energy use. For construction products, EN 15804 sets the indicators and the split into life cycle modules.

This logic has two consequences. First, an EPD does not say "better" or "worse". It says what the carbon footprint and the other indicators are. Second, you may compare results only between declarations made under the same PCR and for the same functional unit. Comparing EPDs from different categories is a method error, not a sales advantage.

What will you find inside such a document? Usually:

A declaration past its validity, or based on old data about raw materials, is no longer evidence, even if it still appears in sales materials.

An independent third party checks the declaration, and the programme operator publishes it. Operators include The International EPD System, IBU in Germany, EPD Norge, BRE in the UK and the Building Research Institute (ITB) in Poland. The check covers the input data, the life cycle model and compliance with the category rules, not only the text of the document.

In construction, Type III is the de facto standard. Declarations follow EN 15804, and an EPD can be a condition for entering a tender or a source of points in LEED and BREEAM. In industry, business customers ask for it more and more often. They calculate their own product carbon footprint and need data from suppliers. Independent EPD verification checks a finished declaration before publication.

Symbols and marks on packaging

Environmental symbols and marks on packagingMost Type II claims appear not in adverts but on packaging, and that is where misuse is easiest. ISO 14021 also covers this layer of communication:

Rules on the circular economy and on producer responsibility now put these marks under closer scrutiny. So they must be more accurate. A symbol without data behind it is the same error as a slogan without data. It is only harder to withdraw, because it is printed on a whole run of packaging.

Environmental declarations for construction products

Environmental declarations for construction productsConstruction is the largest market for Type III declarations, that is EPDs, and it is worth knowing why. The sector accounts for about half of all extracted materials in the EU and for about a third of all waste. So the effect of a product counts twice here. It is a property of the product, and it is also part of the carbon footprint of the whole building.

In practice, this means three things:

  1. EPDs for construction products follow EN 15804. It sets common rules and life cycle modules, so you can compare results from different makers;
  2. programme operators issue the declarations, and an independent third party checks each one; products sold across Europe often go to The International EPD System;
  3. EPD data goes straight into the carbon footprint of buildings, into LEED and BREEAM, and more and more often into tender documents.

For a manufacturer of construction products, a missing declaration starts to work like a missing technical data sheet. It does not stop sales, but it pushes you out of some projects.

How do the declarations differ? A comparison

Comparison of Type I, II and III environmental declarationsThe shortest summary of the differences that decide the choice in practice. It also shows how much each document really says about the environmental properties of a product:

Type I: ecolabelType II: self-declared claimType III: EPD
StandardISO 14024ISO 14021ISO 14025; in construction EN 15804
Who makes the claimthe ecolabel programmethe company itselfthe company, under product category rules (PCR)
Who checks itan independent body within the programmechecking is voluntaryan independent verifier, always
What it says about the productmeets threshold criteria in its categorynames one specific environmental featureresults in several categories, split by life cycle stage
Forma graphic mark on the producta sentence, a symbol or a graphica document of a dozen or more pages with data
Typical useconsumer sales, public procurementproduct communication and marketingconstruction, tenders, business supply chains

What does EU law change, and from when?

EU law on environmental claims and labelsDirective (EU) 2024/825, known as EmpCo, introduces three specific bans in environmental communication. EU countries must apply them from 27 September 2026. Some countries transposed the directive late: in Poland, for example, the bans apply from 27 September 2027. The bans cover:

  1. generic claims such as "environmentally friendly" or "eco" that you cannot support with recognised excellent environmental performance;
  2. your own sustainability labels that are not based on a certification scheme and were not set up by public authorities;
  3. claims that a product is climate neutral because of offsetting.

The wider Green Claims Directive has not come into force. In June 2025, the European Commission announced its intention to withdraw it, and it formally remains a proposal. So plan for EmpCo, not for announcements. EmpCo does not apply in the UK. But the Green Claims Code of the Competition and Markets Authority (CMA) sets similar rules, and the CMA can now fine companies itself.

The conclusions differ for the three types. Type I is based on a recognised certification scheme, and Type III on mandatory verification, so both meet the new requirements by design. The whole burden of proof falls on Type II, because there the company answers for itself, and national consumer authorities check market practices. If your claims are already on the market, a green claims audit checks them before the deadline.

Which type should you choose for your product?

Choosing the type of environmental declarationThe choice depends on what you need and who expects it from you:

The declarations do not exclude each other. A manufacturer can have an EPD for a whole product line, an ecolabel on one model and several self-declared claims on the pack. Each of them must rest on its own documented evidence.

Frequently asked questions

How does an environmental label differ from an environmental declaration?+

An environmental label is a graphic mark on a product, usually awarded by an independent ecolabelling programme (Type I under ISO 14024). An environmental declaration is a document with data: in market practice, this term means an EPD, that is Type III under ISO 14025. The names are often used as synonyms, so the number of the standard is the safest way to tell them apart.

Is an environmental product declaration the same as an EPD?+

Yes. EPD stands for environmental product declaration: a Type III declaration under ISO 14025, based on a life cycle assessment and checked by an independent verifier. In construction, it also follows EN 15804.

Does a self-declared environmental claim need certification?+

No. The company makes a Type II claim on its own responsibility, and the standard does not require certification. But the claim must be verifiable, and the supporting documents must be available on request. Voluntary checks by an independent party make such a claim much more credible.

Which type of declaration is required in construction?+

Type III, that is an EPD under ISO 14025 and EN 15804. It can be a condition for a tender and a source of points in LEED and BREEAM. It also gives input data for the carbon footprint of a building.

Is an environmental declaration a document for authorities or for customers?+

It depends on which one you mean. A declaration under ISO standards, whether an ecolabel, a claim or an EPD, is product information for the market. An EMAS environmental statement describes a whole organisation and is checked by an accredited verifier. The two documents have nothing in common except the name.

How does an ecolabel differ from an ordinary green label?+

An ecolabel is a mark that a programme awards after it checks set criteria, for example the EU Ecolabel. Green labels that a manufacturer designs on its own are Type II self-declared claims. They may be true, but no one checks them. In the EU, your own sustainability labels without a certification scheme are banned from 27 September 2026.

Which declaration shows the effect of a product on the environment over its whole life cycle?+

Type III, that is an EPD. It is based on a life cycle assessment and gives a set of indicators, from the carbon footprint to water and energy use. It covers all stages: from raw materials, through production and use, to waste. An ecolabel and a self-declared claim describe environmental properties only in part.

Can you still use the word "eco" under the new rules?+

Only if you can support the claim with recognised excellent environmental performance. Directive (EU) 2024/825 bans generic claims without such evidence, and your own sustainability labels that are not based on a certification scheme. EU countries must apply these bans from 27 September 2026.

Do you need a declaration that will hold up with customers and regulators?

We carry out LCA studies, environmental product declarations (EPD) and their independent verification: the data behind Type III. Verification against ISO 14021 checks Type II claims, and a green claims audit checks messages that are already on the market.

Contact us
Do you want to base your environmental claims on hard data?
+48 888 242 547 contact@exergy.eco

We use your details only to reply to your enquiry. More in our privacy policy.

See also
Service
Green claims audit
Article
What is greenwashing? Definition and examples for businesses
Article
How to avoid greenwashing? A guide for companies