ISO 14067:2018 sets out how to quantify a product's greenhouse gas emissions and removals over its life cycle in CO₂ equivalent, either cradle-to-gate or cradle-to-grave, with biogenic carbon reported separately. The Digital Product Passport (DPP) comes from the EU Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), and a carbon footprint is one of the things a passport may carry. What a passport must contain is decided product group by product group in delegated acts. Until that act exists for your product, there is no "official passport" to claim.
We cover both topics together because buyers usually ask them together: the EU customer wants a product carbon footprint, and someone has heard a passport will be needed. Calculation first, then the passport.
What ISO 14067 measures
The full title is "Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification". First published in 2018, it was reviewed and confirmed by ISO in 2024, so the 2018 text remains current.
The difference from a corporate inventory (ISO 14064-1, GHG Protocol) is the unit of analysis. A corporate inventory asks what the company emitted in a year. A product footprint asks how much CO₂e one unit of product carries from raw material onward. The same gas bill feeds both, but in the product study it is allocated across products.
System boundary and unit
| Cradle-to-gate | Cradle-to-grave | |
|---|---|---|
| Stages | raw materials, inbound transport, manufacturing (distribution often added) | the same plus use and end-of-life |
| Unit of the result | declared unit (e.g. 1 tonne of pipe) | functional unit (e.g. 1 m² of flooring over 10 years) |
| Typical use | B2B intermediates: steel, aluminium, chemicals, packaging | consumer products, product comparisons |
The unit is where most studies go wrong. In a cradle-to-gate study you do not know how the product will be used, so its function cannot be defined, and the result is given per declared unit. "1 tonne of hot-rolled coil" is a declared unit; "a column carrying load for 50 years" is a functional unit. Presenting a cradle-to-gate number per functional unit invites misleading comparisons.
Allocation in co-production follows the ISO 14044 hierarchy: avoid allocation first (subdivide the process or expand the system), then use a physical relationship such as mass or energy, and only then economic value, with a written justification. Excluded flows and the reason for excluding them belong in the study report. "Negligible" is not enough; the reader should see what was left out.
Biogenic carbon gets its own line
ISO 14067 requires fossil, biogenic and direct land-use-change emissions and removals to be included and documented separately. For a plant using wooden pallets, paper packaging or a biomass boiler, this decides whether the report can be read at all.
We report four lines and never net removals off the headline figure. From a test calculation with hypothetical inputs:
| Component | kg CO₂e per declared unit |
|---|---|
| Fossil (headline) | 1,365.0 |
| Biogenic emissions | 75.0 |
| Biogenic removals | 72.0 |
| Gross (fossil + biogenic emissions) | 1,440.0 |
| Net (gross − removals) | 1,368.0 |
Folding removals silently into the total understates the footprint. Where removals are declared, the permanence and timing of storage need their own documentation. Removals cannot be recorded against fossil carbon.
Worked example: 1 tonne of galvanised pipe, cradle-to-gate
The factors are illustrative. A real study uses supplier declarations or a named database.
| Input | Quantity | Factor | kg CO₂e |
|---|---|---|---|
| Hot-rolled coil (HRC) | 1,044 kg | 2.15 kg CO₂e/kg | 2,244.6 |
| Natural gas | 30.8 kg | 2.72 kg CO₂e/kg | 83.8 |
| Zinc | supplier declaration | (declared) | 31.2 |
| Electricity | 270.6 kWh | 0.469 kg CO₂e/kWh | 126.9 |
| Total | 2,486.5 per tonne of pipe |
About 90% sits in the first row. Every 0.1 kg CO₂e/kg change in the HRC factor moves the result by roughly 104 kg per tonne of pipe, so getting the steel supplier's own ISO 14067 declaration in place of a default factor comes first.
What to check in a supplier's PCF
Most supplier declarations arrive as one number. Before you use it, ask:
- What is the system boundary?
- What is the declared or functional unit?
- Which year and which plant?
- Are fossil and biogenic carbon separated, and were removals netted off?
- Which allocation method was used for co-products?
- Were any flows excluded, and why?
- Has the study been independently verified?
How a PCF differs from CBAM embedded emissions
Steel, aluminium, cement and fertiliser exporters mix these up often. Both give CO₂e per tonne of product; they answer different questions.
| ISO 14067 PCF | CBAM embedded emissions | |
|---|---|---|
| Basis | voluntary international standard | Regulation (EU) 2023/956 and implementing acts |
| Boundary | raw material to gate or grave | installation production processes and precursors |
| Indirect (electricity) emissions | included | counted for cement and fertilisers; for Annex II goods (iron and steel, aluminium, hydrogen) direct only |
| Biogenic carbon | reported separately | under CBAM's own monitoring rules |
| Where it goes | customers, EPDs, later possibly the DPP | customs declaration, certificate obligation |
Electricity, fuel and precursor quantities are shared inputs, but copying an ISO 14067 result into a CBAM declaration, or the reverse, is an error. Our regulation overview has the CBAM notes.
The Digital Product Passport: what the regulation says
The ESPR has been in force since 18 July 2024. The passport provisions work like this:
- The Commission sets ecodesign requirements through delegated acts (Art. 4), each containing at least the elements listed in Article 8, including the definition of the product group covered.
- Where a delegated act requires one, a product may only be placed on the market if a passport is available in line with that act and Articles 10 and 11 (Art. 9(1)).
- The delegated act specifies which data go into the passport, which data carriers are used and where they appear, whether the passport is kept at model, batch or item level, and who can access what (Art. 9(2)).
- Annex III lists the possible elements: product information under Article 7(2)(b) (which can include a carbon footprint), a unique product identifier, a GTIN under ISO/IEC 15459-6, commodity codes such as TARIC, compliance documentation, operator and facility identifiers, importer information, and the service provider holding the backup copy.
- Carbon footprint is one of the product parameters in Annex I (point (n)). Article 7(2)(b) allows a delegated act to require information on performance against those parameters, a carbon footprint included, where appropriate for the product group.
On the infrastructure side, Implementing Decision (EU) 2026/1736 published references to harmonised DPP standards (EN 18216, 18219, 18220, 18221, 18222 and 18223), and Implementing Regulation (EU) 2026/1778 governs the DPP registry. That is infrastructure. At the time of this update we had not found a delegated act that sets the mandatory DPP data for a specific product group.
When can you say "our passport is ready"
What you can honestly say today: "Of the Annex III elements, we hold these and lack those." What you cannot say: "Our product has an official DPP." The mandatory fields, carrier and level are not yet defined.
The product group act may also prescribe a different footprint method from ISO 14067, PEF for example. An ISO 14067 study done now is not wasted, since primary data, allocation decisions and supplier declarations are needed under any method, but do not present its result as the official carbon value of a passport.
A sensible order of work: clean up product and facility identifiers (correct GTIN check digits, known CN/TARIC codes), run ISO 14067 studies with primary data for your top-selling products, and only then trial the data carrier and access layer.
How Carbolyt handles it
The product module on the platform enforces boundary and unit together: choose cradle-to-gate and the unit type switches to declared unit, and use or end-of-life rows are rejected. Fossil, biogenic and land-use-change carbon are kept apart, allocation follows the ISO 14044 order, and an empty exclusions field is written into the report as such. An approved PCF from the supplier portal can fill the ISO 14064-1 Category 4.1 (purchased goods) form; only approved and verified data is passed to the CBAM side.
The passport panel shows which Annex III elements are present, checks GTIN check digits and EORI format, and produces a machine-readable JSON package with a SHA-256 digest. Each published version carries the digest of the previous one; a GS1 Digital Link and QR code are generated, and operator, facility and EORI data stay out of the public layer. The package is labelled as preparatory data and claims no conformity with the harmonised standards. You can request a demo to try it with your own product.
Frequently asked questions
Can an ISO 14067 footprint be used in a CBAM declaration?
Not directly. CBAM embedded emissions follow CBAM's own method, covering the installation's production processes and precursors per tonne of goods, with only direct emissions counted for goods such as iron and steel. ISO 14067 is a life cycle method starting from raw material extraction. Both can draw on the same plant data, but one result does not substitute for the other.
Can a cradle-to-gate study use a functional unit?
Use and end-of-life are excluded, so the product's function cannot be fully defined; the result is expressed per declared unit (for example 1 tonne of pipe). A functional unit makes sense in cradle-to-grave studies.
Can we issue an official Digital Product Passport today?
No. Under the ESPR, the mandatory data, data carrier, passport level and access rights are set by the delegated act for each product group (Art. 9(2)). Until that act exists for your product, a package can only honestly be called preparatory data.
Why is biogenic carbon reported separately?
ISO 14067 requires fossil, biogenic and land-use-change emissions and removals to be documented separately. Without that split, biogenic removals can quietly shrink the fossil figure.
Sources
This article is for information and is not legal advice. Dates and rates reflect the official texts at the time of publication; check the current text before acting.