EN 15804+A2 vs +A1: what changed in 2024 and why it matters

EN 15804 was first published in 2012; the A1 amendment was added in 2013. The +A2 revision approved in 2019 substantially reshaped the architecture of the EU EPD ecosystem. Since 1 September 2024 it has been mandatory for all new EPDs. EPDs published under +A1 remain valid until their expiry, but renewal must move to +A2. This article covers every practical difference encountered during transition.

Indicator set — 7 new additions

EN 15804+A1 had 13 indicators (7 core, 6 additional). +A2 expanded this to 19. The most consequential change is splitting the GWP indicator into four sub-indicators: GWP-total, GWP-fossil, GWP-biogenic and GWP-luluc (land use and land use change). +A1 reported a single GWP; +A2 separates fossil from biogenic carbon. Other additions include three separate eutrophication indicators (EP-freshwater, EP-marine, EP-terrestrial), water deprivation potential (WDP, AWARE-based) and the two ADP sub-indicators (minerals & metals, fossil).

LCIA method — moving from CML toward EF v3.1

+A1 was widely applied with CML 2001 / CML v4.8 2016 methods. +A2 updates indicator definitions to align with the European Commission's Environmental Footprint approach; while the methodology is not formally locked to a single method, EF v3.1 characterisation factors are becoming the de facto standard for most indicators. Under PEFCR, EF is already mandatory. Practical impact: an EPD migrating from A1 to A2 may need to update both the numbers and the methodological reference.

Table numbering change

Under A1 the modulary table was Table 2. In A2 it moved to Table 8; core indicators in Table 8, additional in Table 9, disclaimers in Table 10, resource use in Table 11. Manufacturers copying old report templates verbatim risk verifier rejection if they miss the renumbering. Modern EPD tools (such as clca) generate this numbering automatically per program-operator preference.

Data quality: DQR is now mandatory

A1 left data-quality discussion to the manufacturer; A2 mandates Pedigree Matrix-based DQR on a 1-5 scale. Each inventory item is scored on five dimensions: temporal, geographical and technological representativeness, completeness, and precision. Items with overall DQR > 3.5 require a ±10% sensitivity scenario. This is a frequently missed requirement in legacy EPD renewals.

Modules C and D — end-of-life rules are stricter

A2 clarifies how modules C1-C4 must be reported. The end-of-waste status criteria, the calculation of recycle/recovery percentages and the conditions for claiming Module D credits are tightened. Under A1, Module D was often reported with optimistic assumptions; A2 makes this harder — Module D values trend downward in recycle-heavy categories such as steel and plastics.

A1 → A2 migration checklist

• Split GWP into total / fossil / biogenic / luluc
• Report three eutrophication categories separately (freshwater / marine / terrestrial)
• Compute WDP using the AWARE-based method
• Split ADP into the two sub-indicators (minerals & metals / fossil)
• Review LCIA method reference — EF v3.1 is the recommended direction
• Move the modulary table to Table 8 numbering; sub-tables 9-11
• Score every inventory item with DQR; trigger a sensitivity scenario for items > 3.5
• Re-evaluate Module D claims against the new end-of-waste criteria
• Update disclaimer text to reference A2
• Re-map PCR Part B (if applicable) to a category-specific PCR