Filling the modulary table — 8 common mistakes that get verifier rejection

When verifiers reject an EPD, they almost always see the same 8-10 mistakes. This article walks through them one by one — common lessons from 100+ EPD verifications across the industry.

1. MNR vs MND confusion

MNR (Module Not Reported) means a module is in scope but data is missing. MND (Module Not Declared) means the module is out of scope. A common mistake: marking A4-D as "MNR" in a cradle-to-gate study; the correct flag is "MND". MNR is reserved for genuinely missing data and must be accompanied by a justification.

2. Module chaining — biogenic carbon missing when A1-A3 reported separately

Reporting A1-A3 separately is common, but biogenic carbon requires a chained logic. In wood-based products, biogenic carbon stored in A1 is released at C3 or C4 at end of life. Reports that omit this release fail the "biogenic carbon balance" check — total biogenic carbon over the life cycle must be zero.

3. A4 transport assumption without documentation

A4 covers transport from factory to construction site. Verifiers always ask about the default distance — 100 km average for the German market, 50-200 km for Turkish domestic construction. You must either align with a PCR-permitted default or support the figure with supplier-based actual data. Using 50 km without justification gets rejected.

4. Skipping A5 installation waste

A5 covers installation waste on site. For insulation it is 3-8% (cutting waste), spray insulation 1-2% (overspray), concrete pours 2-5% (residue and rejection). Skipping A5 or setting it to zero is the first verifier flag. PCRs usually mandate a minimum waste assumption — you cannot drop below it.

5. C3-C4 processing splits not matching local regulation

The split between C3 (waste processing) and C4 (disposal) must align with the local waste regulation. In EU countries plastic typically sees 35-45% recycling, 25-35% energy recovery, 20-30% landfill. In Turkey recycling is 20-30% and landfill share is higher. If a manufacturer uses a split inconsistent with local statistics (e.g. all plastic "recycled"), the verifier will flag the contradiction.

6. Inflating Module D credits

Module D reports beyond-system-boundary benefits (the future emission savings from recycling). A2 tightened the "end-of-waste" criterion: the material must actually enter a second market. Being "recyclable" is not enough. 90% recycle rate is defensible for steel; for plastics 30% is the credible level. Claims above this get rejected.

7. Table 11 — negative resource-use values

Table 11 (resource use) includes renewable/non-renewable energy, water use, material use. These can never be negative — there is no physical meaning. Rounding or sign errors in the engine sometimes yield negative values; in the modulary table they should be displayed as 0. Many older tools produce incorrect signs; modern platforms (such as clca) automatically clamp Table 11 within physical bounds.

8. Missing disclaimers

Table 10 disclaimers are an often-forgotten section. EN 15804+A2 mandates practical caveats around biogenic carbon interpretation, end-of-life assumptions and precision level. The Part B PCR adds further disclaimers. ITB Poland verifications mark missing disclaimers as a minor finding; IBU Germany treats them as major findings, extending verification. Using a ready template (as clca does) eliminates this mistake.