Not all DPP data can be self-declared — regulators know that manufacturers have incentives to overstate their sustainability credentials. Certain high-stakes data fields require independent third-party verification before they can be published in a DPP. Here's how the verification system works.
What Requires Third-Party Verification?
- Carbon footprint (batteries): From 2026, carbon footprint declarations in EU battery DPPs must be verified by an accredited body under EN ISO/IEC 17029.
- Recycled content (batteries): Cobalt, lithium, nickel, and lead recycled content percentages require chain-of-custody verification.
- Green claims (Green Claims Directive): Any environmental claim on a product — including claims derived from DPP data — must be pre-approved by a conformity assessment body once the directive is in force.
- Conflict minerals (EU Conflict Minerals Regulation): Responsible sourcing declarations for tin, tantalum, tungsten, gold require independent supply chain audits.
How the Verification Process Works
- Calculate and document: You complete your carbon footprint study or recycled content calculation, following the mandated methodology. This produces a calculation report with all assumptions, data sources, and results documented.
- Engage a verifier: Select an accredited verification body (list available from national accreditation bodies). They sign a verification engagement agreement.
- Document review: The verifier reviews your calculation report, checks methodology compliance, and requests supporting evidence (energy bills, supplier declarations, mass balance records).
- Site visit (for high-assurance verification): The verifier may visit your facility and key suppliers to verify data accuracy.
- Verification statement: The verifier issues a signed verification statement — either "verified without material misstatement" or with exceptions noted.
- Publish in DPP: Upload the verified value and reference the verification statement in your DPP. D-Pass allows you to attach verification documents and reference the verifier's accreditation number.
Choosing a Verifier
- Must be accredited by a national accreditation body (DAkkS in Germany, UKAS in UK, COFRAC in France)
- Must hold accreditation specifically for the relevant standard (ISO 14064, ISO 14067, EN ISO/IEC 17029)
- Must be independent — no financial interest in the company being verified
- Experience in your specific sector is important (battery chemistry knowledge for battery carbon footprint verification)
Verification Costs
Carbon footprint verification for a battery product line: €5,000–€20,000 depending on complexity and site visits. Recycled content chain-of-custody audit: €3,000–€10,000 per year. These costs decline significantly as the methodology becomes more standardised and verifiers gain experience.