PCF Verification Process
A systematic methodology for verifying Product Carbon Footprint statements, ensuring product-level data integrity, methodological consistency, and alignment with applicable standards and PCRs.
This foundational phase ensures that the Product Carbon Footprint verification engagement is appropriately scoped before acceptance. It begins with the collection of product-specific information, including the Product Name and Model, Functional or Declared Unit, Intended Application, Life-Cycle Boundary, production sites, reporting period, and the applicable GHG Statement to be verified.
A key part of this stage is the assessment of the applicable Product Category Rules or equivalent programme rules. Where a mature and applicable PCR exists, we confirm whether the PCF study has been prepared in accordance with its requirements. Where no suitable PCR exists, we assess whether alternative criteria, such as ISO 14067, programme-specific rules, or justified methodological assumptions, are appropriate for the intended use of the PCF statement.
Before engagement acceptance, we also evaluate whether the product category falls within BST’s approved Competency Scope. Verification personnel are assigned based on relevant sector competence, product knowledge, LCA experience, and impartiality requirements. Where specialised technical expertise is required, a technical specialist may be appointed to support the verification team, while the verification conclusion remains the responsibility of qualified verification personnel.
A key part of this stage is the assessment of the applicable Product Category Rules or equivalent programme rules. Where a mature and applicable PCR exists, we confirm whether the PCF study has been prepared in accordance with its requirements. Where no suitable PCR exists, we assess whether alternative criteria, such as ISO 14067, programme-specific rules, or justified methodological assumptions, are appropriate for the intended use of the PCF statement.
Before engagement acceptance, we also evaluate whether the product category falls within BST’s approved Competency Scope. Verification personnel are assigned based on relevant sector competence, product knowledge, LCA experience, and impartiality requirements. Where specialised technical expertise is required, a technical specialist may be appointed to support the verification team, while the verification conclusion remains the responsibility of qualified verification personnel.
Before detailed data testing, the Lead Verifier performs a Strategic Analysis to understand the product system, supply chain structure, manufacturing process, and intended use of the PCF result. This includes reviewing the Functional or Declared Unit, product specifications, system boundary, life-cycle stages, unit processes, cut-off rules, data sources, allocation procedures, and any assumptions or limitations stated in the PCF study.
The verifier also assesses the suitability and hierarchy of applicable criteria, including whether a recognised PCR, programme rule, sector-specific methodology, or ISO-based approach has been applied. If multiple PCRs or methodological options are available, the verification team evaluates the rationale for selection and whether the chosen criteria are appropriate, complete, and consistently applied.
A PCF-specific Risk Assessment is then conducted to identify areas where material misstatements or non-conformities are most likely to occur. Particular attention is given to product complexity, system boundary completeness, upstream and downstream data quality, allocation choices, secondary datasets, emission factors, representativeness of use and end-of-life scenarios, and the reliability of any previous LCA or carbon footprint study used as evidence.
The verifier also assesses the suitability and hierarchy of applicable criteria, including whether a recognised PCR, programme rule, sector-specific methodology, or ISO-based approach has been applied. If multiple PCRs or methodological options are available, the verification team evaluates the rationale for selection and whether the chosen criteria are appropriate, complete, and consistently applied.
A PCF-specific Risk Assessment is then conducted to identify areas where material misstatements or non-conformities are most likely to occur. Particular attention is given to product complexity, system boundary completeness, upstream and downstream data quality, allocation choices, secondary datasets, emission factors, representativeness of use and end-of-life scenarios, and the reliability of any previous LCA or carbon footprint study used as evidence.
Based on the strategic analysis and risk assessment, the Lead Verifier develops a formal Verification Plan and Evidence-Gathering Plan in accordance with BST’s SOP100 methodology. The plan defines the verification objectives, scope, criteria, assurance level, materiality, team responsibilities, schedule, and whether verification activities will be conducted remotely, on-site, or through a hybrid approach.
For PCF engagements, the evidence-gathering plan is designed around the product life cycle rather than only organisational emission sources. It identifies the testing approach for Raw Materials, Manufacturing, Transport, Use Phase, End-of-Life, and any excluded or cut-off processes. Sampling is prioritised based on contribution to total product emissions, uncertainty, data source reliability, and the risk of methodological inconsistency.
The plan also defines how the verification team will test key PCF-specific elements, including PCR conformity, functional unit consistency, bill of materials, mass and energy balances, supplier data, allocation methods, database selection, emission factor appropriateness, data quality indicators, and recalculation of material GHG contributions.
For PCF engagements, the evidence-gathering plan is designed around the product life cycle rather than only organisational emission sources. It identifies the testing approach for Raw Materials, Manufacturing, Transport, Use Phase, End-of-Life, and any excluded or cut-off processes. Sampling is prioritised based on contribution to total product emissions, uncertainty, data source reliability, and the risk of methodological inconsistency.
The plan also defines how the verification team will test key PCF-specific elements, including PCR conformity, functional unit consistency, bill of materials, mass and energy balances, supplier data, allocation methods, database selection, emission factor appropriateness, data quality indicators, and recalculation of material GHG contributions.
During execution, the verification team performs evidence-gathering activities to determine whether the PCF statement is materially correct and conforms to the applicable criteria. Activities may include document review, interviews, data tracing, recalculation, cross-checking, supplier evidence review, analytical testing, and assessment of controls over product data collection and calculation.
The team verifies whether the product system has been accurately represented, including the consistency between the product specification, bill of materials, production records, process flow, activity data, and the PCF model. Where a PCR is applicable, the team checks whether mandatory life-cycle stages, data quality rules, allocation hierarchy, cut-off requirements, reporting format, and disclosure requirements have been followed.
For primary data, the team may verify production volumes, material inputs, energy consumption, waste generation, logistics data, and process-specific parameters against source records. For secondary data, the team assesses the appropriateness, geographical and temporal representativeness, technological relevance, and documentation of emission factors or LCA database records. Any misstatements, non-conformities, data gaps, or unjustified assumptions are logged, communicated, and evaluated for materiality.
The team verifies whether the product system has been accurately represented, including the consistency between the product specification, bill of materials, production records, process flow, activity data, and the PCF model. Where a PCR is applicable, the team checks whether mandatory life-cycle stages, data quality rules, allocation hierarchy, cut-off requirements, reporting format, and disclosure requirements have been followed.
For primary data, the team may verify production volumes, material inputs, energy consumption, waste generation, logistics data, and process-specific parameters against source records. For secondary data, the team assesses the appropriateness, geographical and temporal representativeness, technological relevance, and documentation of emission factors or LCA database records. Any misstatements, non-conformities, data gaps, or unjustified assumptions are logged, communicated, and evaluated for materiality.
After evidence gathering is completed, the Lead Verifier evaluates whether sufficient and appropriate evidence has been obtained to support the verification conclusion. This includes assessing the remaining verification risk, unresolved findings, materiality, conformity with applicable PCR or programme criteria, and the reliability of the PCF calculation model and supporting evidence.
The draft Verification Opinion and supporting records are then submitted for Independent Review. The Independent Reviewer confirms that the verification team had the necessary competence, that the verification plan addressed the PCF-specific risks, that the evidence supports the conclusion, and that the opinion is consistent with BST’s SOP100 requirements and the applicable verification criteria.
Upon successful technical review and approval, BST issues the final Verification Opinion and, where applicable, the Verification Report. The final output identifies the verified product, functional or declared unit, reporting period, applicable criteria, level of assurance, materiality, scope boundary, limitations, and conclusion on whether the PCF statement is materially correct and prepared in accordance with the selected criteria.
The draft Verification Opinion and supporting records are then submitted for Independent Review. The Independent Reviewer confirms that the verification team had the necessary competence, that the verification plan addressed the PCF-specific risks, that the evidence supports the conclusion, and that the opinion is consistent with BST’s SOP100 requirements and the applicable verification criteria.
Upon successful technical review and approval, BST issues the final Verification Opinion and, where applicable, the Verification Report. The final output identifies the verified product, functional or declared unit, reporting period, applicable criteria, level of assurance, materiality, scope boundary, limitations, and conclusion on whether the PCF statement is materially correct and prepared in accordance with the selected criteria.