Start with an existing product-verification capability and define the missing coverage
The practical choice is an assignment the body can accept and substantiate. Matching ISO numbers are the beginning of that assessment.
Propose an integrated assessment of the method and operating controls, independent verification of sampled product results, and checks through to the consumer-facing rating. Ask the CAB to identify precisely which parts it can issue under accreditation and what further scheme or programme acceptance is required.
| Route | Where it helps | What must be established |
|---|---|---|
| 1. Product-carbon verification with system assessment First route to qualify | Uses relevant ISO 17029 / 14065 accreditation with ISO 14067 product scope. Operating controls and a defined population of existing results provide a concrete starting assignment. A CFP systematic approach may support repeated calculations where applicable. | Programme acceptance, eligible organisation and products, sector competence, verification versus validation, remote evidence, rating and trader-use coverage, and the statement the body can actually issue. |
| 2. ISAE 3000 assurance alongside the required technical work Complementary | Can assess defined system controls or other suitable non-financial subject matter. It may let one engagement team coordinate method, system and sampling work, subject to competence and independence. | Named criteria, assurance level, reporting period and boundaries; identify separately any accredited product verification. An ISAE report alone does not establish conformity with all ESFC requirements. |
| 3. Product / process / service certification under ISO 17065 Alternative architecture | A possible certification-scheme design. ISO 17065 is expressly mentioned in the Directive's recital 7; it is not excluded in principle for environmental labels. | An appropriate certification programme, technical competence and relevant scope, plus an ESFC decision if changing its current route. Availability and lead time must be assessed for that actual programme. |
Why qualify route 1 first? Public registers demonstrate existing product-verification capability, including at KPMG Cert. Our inference is that building on relevant capability may reduce the work needed to reach an offer. Neither the register nor a standard guarantees a short lead time. A paid, bounded feasibility phase can resolve acceptance questions before the substantive assessment, with clear deliverables and a decision to proceed or stop.
What counts as progress? A signed engagement confirms that work has been commissioned. Permission to use a scheme label needs the required substantive assessment outcome and an effective scheme decision. A contract, provisional listing or customer opt-in does not supply that outcome.
Law, scheme rules and accreditation coverage
The legal requirement. From 27 September 2026, the amended unfair-commercial-practices rules prohibit sustainability labels that are neither based on a certification scheme nor established by a public authority. The scheme definition includes public requirements, open access, stakeholder consultation, action on non-compliance and independent monitoring of trader compliance. It does not prescribe one mandatory ISO number. Recital 7 names ISO 17065 and accreditation mechanisms as examples for demonstrating the monitoring body's competence and independence. These requirements concern the whole arrangement. Directive (EU) 2024/825, recital 7, Article 1 and Article 4.
The ESFC route. The published ESFC draft specifies ISO 17029 / 14065 with ISO 14067 product scope. That is a scheme choice within a broader legal framework. Changes to its treatment of system assessment, verification and complementary assurance require the scheme's own adoption process. Published scheme documents.
The accredited assignment. Accreditation applies to a body's specified activities and scope. The relevant programme and the proposed engagement must fit that scope. The CAB must resolve any required programme recognition or scope extension before representing the affected work as accredited. The same body can offer both accredited and unaccredited services.
Calculation criteria, verification, competence and assurance
| Reference | Function | Application to a rating service |
|---|---|---|
| ISO 14040 / 14044 | Life-cycle assessment principles, framework and requirements. | Methodological basis. A method review and a conclusion about live trader claims are different deliverables. ISO 14040 · ISO 14044. |
| ISO 14067:2018 | Quantification and reporting of a product carbon footprint (CFP), consistent with LCA standards. | Technical criteria for footprints. Communication is outside its scope; rating benchmarks and public use need additional criteria. Annex C addresses a CFP systematic approach. ISO description. |
| ISO 14064-3:2019 | Verification and validation of greenhouse-gas statements. | Planning, risk, evidence, materiality and conclusions. Define the claim before choosing verification of historical information or validation of prospective assumptions. ISO description. |
| ISO/IEC 17029:2019 | Competence, impartiality and consistent operation of validation/verification bodies. | Requires an applicable programme. Pre-engagement review determines whether the body can undertake the work; independent review and decision are part of the process. ISO description. |
| ISO 14065:2020 | Environmental-information requirements for those bodies. | Annex E connects GHG engagements to ISO 14064-3. E.3.2 requires assessment of the continuing effectiveness of a CFP systematic approach when used. ISO description. |
| ISAE 3000 (Revised) | Assurance outside audits or reviews of historical financial information. | Reasonable or limited assurance over defined subject matter against suitable criteria. Potentially useful for system controls; accreditation and scheme coverage must be identified separately. IAASB standard. |
| ISO/IEC 17065 | Certification of products, processes and services. | A possible alternative architecture, subject to a suitable programme and scheme decision. Holding unrelated 17065 scopes is not proof of climate-rating coverage. ISO description. |
CFP systematic approach is a generic concept
CFP means product carbon footprint. A CFP systematic approach is a controlled, repeatable way to produce footprints for multiple eligible products under ISO 14067 Annex C. It is not an SGS product. A verification programme supplies the rules and procedures by which a body assesses the work; different bodies and accreditation systems can operate different programmes.
A shared software platform does not automatically turn unrelated restaurants into one eligible organisation. The assignment must identify who controls the data and calculations, which products and organisations it covers, and how trader evidence enters the assessment. “Systematic” also means continuing control and reassessment of relevant changes, rather than unlimited approval of future outputs. ISO 14067, Annex C; ISO 14065, E.3.2.
Where ISAE 3000 and SOC can help
The correct name is ISAE 3000 (Revised). For a digital service, a suitably scoped engagement can examine controls such as authorised input changes, version management and reproducible processing. The report must state the criteria, period, assurance level and limitations. This application to calculation controls is a proposed use of the standard. IAASB.
SOC describes services concerning organisational controls. SOC 2 addresses security, availability, processing integrity, confidentiality or privacy. Such work can provide useful evidence for a digital assessment, but its title does not establish correct product footprints or compliant restaurant ratings. AICPA SOC services.
A combined engagement should map each requirement to its criteria, tests, responsible legal entity and final statement. It must make clear which work is accredited. The practitioner should also confirm the applicable sustainability-assurance framework, including the transition to ISSA 5000 where relevant. IAASB ISSA 5000 guidance.
From the source record to the displayed rating
A concrete assignment for CAB review. The programme determines the final design and the evidence needed.
- Define the statement and population. Pin the method, data, software and benchmark versions; products, responsible organisations, period, surfaces and assurance level. Distinguish existing results from any prospective claims.
- Assess the method and operating controls. Review boundaries, source data, allocation, calculation logic, benchmark mapping, access controls and change management. Establish whether the CFP systematic approach is applicable and covered.
- Select cases independently. The CAB selects risk-based and random cases from a complete population. Provider regression tests and internal sampling support the evidence; they do not replace independent selection and investigation.
- Trace each selected case end to end. Inspect original recipe or product records, quantities and relevant supporting evidence; reproduce the footprint and rating; check the value, wording and format actually displayed. Include letter or star formats where the scheme permits them.
- Resolve findings and make an independent decision. Determine whether errors affect an individual case or a wider group. Record corrections, exclusions and limitations before issuing the appropriate statement. Keep confidential case evidence separate from the agreed public status or summary.
- Maintain coverage. Monitor changes, complaints and trader use; repeat independent sampling and assess continued system effectiveness under the programme. Define when new evidence, reassessment or suspension is required.
Can this be fully remote?
There is a basis for proposing remote work, but no universal waiver. ISO 14064-3 §6.1.4.2 lists initial verification among the circumstances requiring a site or facility visit, but permits a justified, documented decision to omit it based on the risk assessment and evidence-gathering plan, considering any prior verification. The CAB must also satisfy its programme and accreditation rules. Remote access needs to provide sufficient, reliable evidence, including direct access to original trader records and evidence of actual display. ISO 14064-3:2019.
Provider terms can establish cooperation, data-access and correction obligations. Those terms must be effective for the relevant traders, and the records must actually be accessible. A contractual clause alone is not verification evidence.
Programme-specific constraint: Accredia Circular 08/2025 §3.1 specifies initial site work for its CFP Systematic Approach route. Its allowance for a different risk-based sampling approach above 100 CFP per year concerns surveillance sampling; it does not by itself waive initial visits. This Italian programme rule should neither be ignored nor applied automatically to every other accreditation system. Accredia circular, pp. 21–22.
Which CABs have a relevant starting scope?
Selected, identifiable legal entities with primary register evidence. This is not an exhaustive census or a list of appointed ESFC bodies. Availability and assignment acceptance are separate from accreditation.
| Legal entity | Public scope evidence | Remaining qualification |
|---|---|---|
| KPMG Cert GmbH Umweltgutachterorganisation | Active DAkkS entry D-VS-16103-01-01. The annex, §6, lists ISO 14067 product verification with ISO 14064-3 under the 17029 / 14065 framework. | A relevant candidate for product verification. Confirm ESFC criteria, system and trader-use coverage, remote procedure and any complementary assurance assignment. The annex does not establish product validation or ESFC acceptance. |
| CSQA Certificazioni S.r.l. | Accredia 00070, VV annex rev. 005, 13 July 2026, explicitly includes CFP single-product and CFP Systematic Approach. | Direct evidence that the systematic-approach programme is not exclusive to SGS. Check eligible organisation, programme visit rules, sector fit and the additional rating / trader-use requirements. |
| TÜV Italia S.r.l. (TÜV SÜD) | Accredia 00077 lists ISO 14067 CFP verification and validation with 17029 / 14065. | Confirm the specific programme, systematic-approach coverage if used, remote feasibility and ESFC acceptance. This is a different legal entity from TÜV SÜD Industrie Service in Germany. |
| SGS ICS Italia S.r.l. | Accredia 02242 lists ISO 14067 CFP verification and validation with 17029 / 14065. | The exact issuing entity and programme must match the offer. A group's accredited CFP capability does not establish that a particular methodology or ESFC assignment can be delivered under that accreditation. |
| TÜV SÜD Industrie Service GmbH | DAkkS D-VS-14153-01-01, product-verification scope. | Qualify the German verification route separately from TÜV Italia's activities. Project validation elsewhere in an annex must not be read as product validation. |
| TÜV Rheinland Energy & Environment GmbH | DAkkS D-VS-11120-01-01, product-verification scope. | Assess this entity's programme directly. Another TÜV Rheinland entity's scope or availability does not determine its eligibility. |
| DEKRA Certification GmbH | DAkkS D-VS-16029-01-01, product-verification scope. | This evidence belongs to DEKRA Certification GmbH. It cannot be transferred to DEKRA Assurance Services or other group companies. |
Additional register-evidenced candidates: GUTcert, TÜV NORD CERT, Müller-BBM Cert, verico SCE, TÜV Hessen and TÜV Thüringen have product-verification entries in the September register review. The same programme, competence and engagement checks apply.
Other assurance and methodology partners, including Bureau Veritas: a method-review proposal may cover a useful part of the assignment. Obtain the exact issuing legal entity, standard and deliverable before counting that work as accredited product verification or independent monitoring of ratings. A brand name or a Function 1 review is insufficient evidence of full coverage.
Working outreach lists can be broader than this table. Their totals count leads, not bodies confirmed to accept the complete engagement. Accreditation annexes, rather than marketing pages or group-level credentials, should settle the scope question.
What the CAB's proposal should resolve
- Issuer and programme: contracting and statement-issuing legal entities, current accreditation annex, applicable programme, and any acceptance or extension needed.
- Coverage: a short mapping of method review, system controls, product results, rating allocation and trader display to criteria, tests and deliverables. Identify gaps explicitly.
- Evidence and remote execution: population, independent sampling plan, source-record access, programme visit rules and the reasoned remote approach.
- Assurance and reporting: verification or validation, assurance level, materiality, period, independent review and decision, confidential report and public statement boundaries.
- Effort and acceptance gates: feasibility work, substantive assessment, corrections and surveillance; fees, inputs, realistic milestones and the conditions for proceeding. Programme development must preserve impartiality and avoid designing the provider's solution and then assessing that same work.
Primary sources and what remains a proposal
Updated . Legal interpretation is grounded in the linked EU text. Standards roles and clause references were checked against official publications and licensed ISO texts; no licensed full text is reproduced. CAB entries link to the responsible accreditation registers and annexes. Most German entries were reviewed on 4 September; KPMG's active listing and the highlighted Italian entries were checked on 8 September.
The integrated workflow, remote evidence design and recommendation to qualify route 1 first are research conclusions for CAB and scheme-owner review. Public scope evidence does not establish commercial availability, an accepted ESFC programme, or a completed assessment. Bilateral correspondence and confidential customer information are not published here.
Programme references: ISO 17029 §§8 and 9.2 address an applicable programme and pre-engagement review, including a programme that is to be established; ISO 14065 Annex E and ISO 14067 Annex C connect repeatable CFP production with continuing system assessment. ISO 17029 · ISO 14065 · ISO 14067.
Assurance references: ISAE 3000 (Revised), particularly engagement acceptance and report content, is published in IAASB Handbook, Volume III. ISO CASCO's description of assessment bodies explains why product certification, system certification and validation/verification have different functions.
Return to the scheme documents or published certification status.