
Impacts, Risks, and Opportunities (IRO) for CSRD Reporting
In this article, we’ll break down what IROs are, how to identify and assess them, and what CSRD requires in terms of disclosure.
ESG / CSR
Industries


By Stephanie Safdie, US Copywriter, on 30/11/2022
Updated by Agnès Potier-Murphy, on 23/06/2026


ISO 14067 is the international standard for calculating and reporting a product's carbon footprint, covering every stage of its life, from raw material extraction to disposal. Whether the product is a smartphone, a pair of sneakers, or a metal bolt, the standard provides a single, verifiable emissions figure that companies can use to substantiate environmental claims, meet supply chain data requests, and comply with an increasingly demanding regulatory landscape.
Regulators, investors, and enterprise customers across the EU are now asking for product-level carbon data in a form that can be independently verified. This article explains what ISO 14067 requires, how the measurement process works, and why the standard has moved to the centre of sustainability compliance for product-based businesses.
What ISO 14067 is and how it differs from other ISO standards
How the 5 life cycle assessment (LCA) stages of a product carbon footprint work — and where emissions tend to concentrate
What ISO 14067 verification actually involves, and why it is not a certification scheme
How the EU’s ECGT Directive is changing the rules on environmental claims from September 2026
Why CSRD supply chain requirements are driving demand for ISO 14067-aligned product data
ISO 14067 is the leading international standard for quantifying the carbon footprint of a product (CFP). While other standards look at a company’s overall office or factory emissions, ISO 14067 zooms in on the individual product, tracking every gram of greenhouse gas (GHG) emitted from the moment raw materials are extracted to the moment the product is disposed of or recycled.
Importantly, ISO 14067 is built on the Life Cycle Assessment (LCA) framework defined in ISO 14040 and ISO 14044. This means it does not replace these standards, but applies their principles specifically to carbon footprinting.
The primary goal of ISO 14067 is to provide a clear, verifiable figure for a product’s total climate impact, expressed in mass of CO₂ equivalent (CO₂e) per functional unit.
What is a Functional Unit? A key requirement of ISO 14067 is defining a "functional unit" to ensure fair comparison. For example, instead of just measuring a box of detergent, a company would measure the carbon footprint per 100 washes. This allows for an objective assessment of efficiency and impact across different product designs.
ISO 14067 places strict conditions on comparability. Products can only be compared if they use the same functional unit, system boundaries, data assumptions, and methodological choices. Without this alignment, comparisons can be misleading and are not considered compliant.
A product carbon footprint is the total amount of greenhouse gas emissions generated across a product’s entire life cycle, expressed as a single figure in kilograms or tonnes of CO₂ equivalent (CO₂e). It covers everything: the energy used to mine raw materials, the emissions from manufacturing, the fuel burned in transport, the electricity consumed during use, and the impact of disposal.
The PCF is what ISO 14067 produces. It is a specific, science-based figure: independently verifiable, disclosable to customers, embeddable in a Digital Product Passport, and usable to substantiate an environmental claim.
Understanding what a product carbon footprint is and how it is calculated is a useful starting point before going deeper into the ISO 14067 methodology.
To calculate an accurate carbon footprint, ISO 14067 typically uses a cradle-to-grave approach, but also allows for cradle-to-gate assessments where justified. This means looking beyond the factory walls to account for greenhouse gas emissions at every physical stage of a product’s existence.
The Cradle
This includes extracting resources (mining, farming) and the energy used to transport them to the first processing site.
The actual creation of the product, including energy used by machinery and emissions from chemical processes or factory waste.
The impact of moving finished goods to warehouses, retailers, or directly to consumers via sea, air, or road.
Emissions generated while the consumer uses the product (eg. the electricity a refrigerator consumes over ten years).
The Grave
This covers the energy needed for recycling or incineration, and the emissions produced as materials break down in a landfill.
The goal of this 5-stage mapping is to identify carbon hotspots — the specific areas where a product’s environmental impact is highest.
The distribution of emissions varies significantly by product type. For mains-powered equipment such as servers and desktop computers, the use phase tends to dominate: a server running continuously over several years will accumulate far greater operational emissions than its manufacturing footprint. For battery-powered consumer devices like laptops, the picture is often reversed: research based on Dell product carbon footprint data shows that embodied carbon from manufacturing typically accounts for around 80% of total lifecycle emissions, with the use phase making up the remaining 20%.
This kind of visibility is exactly what ISO 14067 is designed to produce. Once a company knows where its emissions are concentrated, it can act on that information.
To ensure consistency and comparability across similar products, many ISO 14067 studies follow Product Category Rules (PCRs). These rules define system boundaries, data requirements, and calculation methods for specific product categories, helping ensure results are aligned and audit-ready.
By using this data-driven view, businesses can:
It is common for businesses to confuse ISO 14067 with other ISO standards. While they all fall under the sustainability umbrella, they serve very different purposes. Choosing the right one depends on whether you want to improve your internal processes or verify a specific product's impact.
Standards like ISO 14001 (Environmental Management) and ISO 50001 (Energy Management) focus on processes. They provide a framework for how a company should manage its environmental impact or energy use.
To prove that your company has a system in place to monitor and reduce its environmental footprint.
Improved operational efficiency and regulatory compliance for the entire organisation.
ISO 14064 is often confused with ISO 14067, but their scopes are different. ISO 14064 measures the greenhouse gas emissions of an entire company (Scope 1, 2, and 3) over a specific period, usually a year.
To report a corporate-level carbon footprint for ESG reporting or investor disclosures.
A structured and auditable greenhouse gas inventory that supports ESG reporting, target setting, and, where applicable, third-party verification.
Unlike the others, ISO 14067 is product-specific. It doesn't look at your office's recycling habits or your corporate fleet unless they directly contribute to the life cycle of a specific product.
To provide a verified carbon value for an individual good or service (e.g., “This laptop has a footprint of 250kg CO₂e”).
Data that can be used for eco-labeling, Digital Product Passports, and meeting specific customer demands for low-carbon products.
Quick glance summary of benefits:
| Standard | Focus | Best For... |
|---|---|---|
|
ISO 14001
|
Management Processes | Demonstrating overall environmental commitment. |
|
ISO 50001
|
Energy Efficiency | Reducing energy costs and industrial consumption. |
|
ISO 14064
|
Corporate Emissions | Annual ESG reporting and carbon neutrality pledges. |
|
ISO 14067
|
Product Life Cycle | Product labeling, supply chain transparency, and green claims. |
The EU's ECGT Directive, Digital Product Passports, and CSRD supply chain requirements are all, in different ways, creating demand for the same thing: verified, product-level carbon data. ISO 14067 is the standard most widely used to produce it.
From 27 September 2026, the EU’s ECGT Directive prohibits generic claims like “eco-friendly” or “carbon neutral” unless substantiated by verified data.
Non-compliance risks penalties of up to 4% of annual turnover. ISO 14067 provides the scientific methodology needed to produce the auditable data required to defend your claims.
The EU’s ESPR introduces Digital Product Passports (DPPs) across sectors between 2026 and 2028, requiring verified, product-level carbon data for compliance.
ISO 14067 is the industry-standard framework to produce this carbon data, ensuring your products are passport-ready the moment sector requirements go live.
ISO 14067 maps full supply chain emissions, uncovering hidden inefficiencies where material and energy costs are often concentrated.
Pinpointing these hotspots allows you to redesign high-impact processes, simultaneously cutting your carbon footprint and your operational costs.
Many ESG frameworks and investor due diligence processes now require product-level Scope 3 data, and a verified ISO 14067 study is one of the few methodologies that produces it in a form auditors will accept.
For companies seeking to demonstrate climate credibility to institutional investors or enterprise customers, a methodology-backed PCF report is considerably more defensible than a corporate carbon neutral pledge.
The regulatory landscape for environmental claims in the EU has shifted considerably. The standalone Green Claims Directive, originally proposed by the European Commission in 2023, was withdrawn in June 2025 following political opposition. For companies that had hoped the withdrawal would ease pressure on greenwashing compliance, the reality is different, as enforcement is accelerating rather than softening.
The Empowering Consumers for the Green Transition Directive (ECGT), Directive (EU) 2024/825, was adopted in February 2024 and is already law. Member states were required to transpose it into national legislation by 27 March 2026, and enforcement begins on 27 September 2026. It prohibits a range of commercial practices that have until recently been widespread: generic claims such as "eco-friendly," "green," and "sustainable" without specific substantiation; sustainability labels not based on a recognised certification scheme or public authority; and — critically — product-level claims of "climate neutral" or "carbon neutral" where those claims rest on carbon offsets rather than actual lifecycle reductions.
Under Article 13 of the Directive, member states are required to set penalties of at least 4% of the trader's annual turnover in the relevant member state, or at least €2 million where turnover cannot be established. Countries may set higher penalties, and several already do.
ISO 14067 is the internationally recognised methodology for producing the lifecycle data needed to substantiate product-level environmental claims. A company that has conducted an ISO 14067-compliant carbon footprint study is in a far stronger position to defend its claims under the ECGT enforcement framework, and to demonstrate to regulators exactly how its figures were arrived at.
The EU's Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024, introduces Digital Product Passports (DPPs) across product categories on a phased timeline. Iron and steel have an indicative first delegated act in 2026, with textiles and aluminium following in 2027 and furniture in 2028; once a delegated act is adopted for a given sector, businesses have 18 months before compliance is required.
DPPs are designed to carry verified product-level environmental data, and the carbon footprint field of a DPP is precisely the kind of output an ISO 14067 study produces. While ISO 14067 is not itself mandated as the required methodology, it is the most widely used standard for this purpose and provides the rigour that DPP frameworks expect.
European Commission
Implementing the Ecodesign for Sustainable Products Regulation, 2024
For companies in sectors approaching their DPP timeline, beginning an ISO 14067 study now means the data is ready before it becomes a compliance deadline. More information on the ESPR framework can be found in Greenly's guide to the Ecodesign for Sustainable Products Regulation.
Under the Corporate Sustainability Reporting Directive (CSRD) and its associated ESRS E1 climate standard, companies in scope are required to report greenhouse gas emissions across their value chain, including Scope 3 emissions from suppliers and downstream activities. Following the Omnibus I Directive adopted in February 2026, the estimated number of companies directly in scope for CSRD has narrowed significantly, to around 5,000 large undertakings. But the downstream effect reaches considerably further.
When a large company in scope for CSRD needs product-level emissions data from its supply chain, it asks its suppliers to provide it. Those suppliers — many of them smaller businesses not directly subject to CSRD — face a choice: provide the data or risk losing the contract. ISO 14067 is the standard most widely used to produce that product-level data in a form that is methodologically defensible and audit-ready.
For suppliers in manufacturing, electronics, textiles, and other product-intensive sectors, an ISO 14067-aligned PCF report is increasingly the expected response to that request.
In the past, achieving ISO 14067 was a marathon of manual spreadsheets and expensive consultants that could take the best part of a year. Today, that has changed. While the standard remains as rigorous as ever, modern technology has transformed verification from a headache into a real-time business tool.
To credibly communicate alignment with ISO 14067, it takes more than a number: you need a robust and transparent Product Carbon Footprint (PCF) report, which is often independently verified for external use.
It is important to note that ISO 14067 is not a certification scheme. Unlike standards such as ISO 14001, there is no official 'ISO 14067 certification'. Instead, organisations demonstrate conformity through documented methodology and, where needed, third-party verification.
Every study starts by setting the rules.
Your measurement baseline — for example, emissions per “1,000 units” or “1kg of product”.
Most modern requirements use a Cradle-to-Grave approach, covering everything from raw material extraction to final disposal.
The Life Cycle Inventory is often the most difficult stage because it requires data on every material, energy input, and transport leg.
Sending hundreds of emails to suppliers and manually searching databases for emission factors.
Upload a Bill of Materials (BOM), then match raw data to the correct factors from a large database in days rather than months.
ISO 14067 requires carbon calculations that are traceable, defensible, and scientifically aligned.
Use verified global databases to keep calculations aligned with recognised scientific standards.
Greenly’s methodology review ensures the final dataset is ready for auditor scrutiny and ISO compliance.
The footprint is the starting point: the real objective is using it to improve the product.
Test what-if scenarios, such as replacing virgin plastic with recycled aluminum, directly within the platform.
Apply the same methodology across an entire product line instead of rebuilding every analysis from scratch.
To make claims official, an independent third-party auditor must review the work.
Greenly produces a transparent report detailing every assumption and data source, making final verification smoother and more predictable.
While ISO 14067 is the gold standard for product transparency, achieving it isn't without hurdles. Most companies encounter roadblocks during the process. Here is how to navigate them:
To be ISO-compliant, you need accurate carbon data from suppliers. However, many suppliers—especially deeper in the supply chain—lack this data or are reluctant to share it.
Use a hybrid approach: start with secondary data to build your model, then prioritise collecting primary data from the small set of suppliers responsible for the majority of emissions.
It can be unclear which activities should be included—such as whether design offices or only manufacturing sites count toward the footprint.
Follow Product Category Rules (PCR), which define exactly which life cycle stages must be included, ensuring consistency and audit compliance.
When multiple products share the same production line, it becomes difficult to assign energy use and emissions accurately.
Apply ISO’s allocation hierarchy: first isolate processes where possible, otherwise distribute impacts based on physical metrics like weight or volume.
Carbon footprints quickly become outdated when suppliers, materials, or logistics change.
Move toward dynamic, software-based accounting systems that automatically update footprints as your supply chain evolves.
The timeline depends on your data readiness. A single product assessed with a modern LCA platform typically takes 2–4 weeks. A full consultant-led study for a complex product, including independent third-party verification, generally takes 3–6 months. Starting with clean, well-structured supplier data makes a significant difference either way.
The ISO 14067 standard itself is voluntary: you can follow its methodology for internal analysis or supply chain optimisation without an external audit. However, if you intend to communicate your product's carbon footprint publicly — on packaging, in marketing, or to meet regulatory or customer requirements — independent verification is widely expected and may be required under emerging frameworks such as the ECGT Directive.
ISO 14064 measures the greenhouse gas emissions of an entire organisation over a given period, the corporate-level carbon footprint used for ESG reporting. ISO 14067 operates at the product level, quantifying the emissions associated with a single product across its entire lifecycle. The two standards are complementary and often used alongside each other, particularly where CSRD reporting requirements create demand for both organisational and product-level data.
No. ISO 14067 is not a certification scheme, and no official "ISO 14067 certificate" is issued. Organisations demonstrate conformity through a documented, methodologically rigorous carbon footprint study, which can then be independently verified by a third-party auditor. The result is a verified PCF report, not a certificate.
There is no set expiration date in the standard itself, but in practice, many organisations update reports every 2 to 3 years or when significant changes occur in the product’s carbon footprint due to new materials or processes. The definition of a “significant change” is not specified in ISO 14067 and may vary depending on the program or stakeholder requirements.
Yes. Although we often talk about products, ISO 14067 applies to services as well. For a service, the life cycle includes the energy used in data centers, the travel of personnel, and any physical materials used during the delivery of that service.
Not directly — the standard itself is voluntary. However, it is increasingly required in practice. Customers subject to CSRD may request ISO 14067-aligned data from their suppliers. Digital Product Passport frameworks under the ESPR will require product-level carbon data in forms that ISO 14067 is well-positioned to produce. And the ECGT Directive's ban on unsubstantiated product claims makes ISO 14067 an important part of any defensible green claims strategy.
