Why a standards-first design
The accreditation standard is chosen first because it determines what is attested, who is competent to attest it, and how a directive reviewer reads the word “verification” — and, decisively, which accredited bodies actually exist to do the work.
A certification scheme inherits most of its credibility from the accreditation standard underneath it. The standard determines what is actually being attested, who is competent to attest it, and how an EU Directive 2024/825 reviewer reads the word “verification.” Choosing it first — before the rating thresholds, the database, or the label artwork — keeps every later decision anchored to an internationally recognised conformity-assessment framework rather than to a scheme-specific invention.
The choice also decides the eligible pool of accredited bodies — and for EmpCo that proved decisive. A standard that accredits product and process certification (ISO/IEC 17065:2012, the family used by established food-and-environment programmes such as the Marine Stewardship Council, Rainforest Alliance, and Origin Green) points to one set of bodies; a standard that accredits validation and verification of environmental information (ISO/IEC 17029:2019 + ISO 14065:2020) points to a different set. A systematic review of accreditation registers on 8 July 2026 found that no ISO/IEC 17065 accreditation with an LCA, product-carbon-footprint or rating scope exists in any register checked, while at least 18 bodies hold ISO/IEC 17029 + ISO 14065 accreditation with an explicit ISO 14067 product scope — confirmed in the nine registers checked, a lower bound. EmpCo is therefore structured as a third-party verification scheme — the directive's own operative wording — anchored on ISO/IEC 17029 + ISO 14065: the provider's assessment pathway is validated once as a system, and its live claims are verified by annual sampling. The sections below set out the full set of standards weighed and the reasoning behind that choice.
Which accreditation standard does the validation/verification body need?
This table answers three questions an accredited body or directive reviewer actually asks: which accreditation must the VVB hold, what happened to the recital's ISO 17065 example, and which standards are ruled out — and why. The rows are grouped in that decision order: the route that works first, then the standards the scheme depends on, then the standards that cannot serve as the anchor. Neighbouring scheme and methodology standards — which define adjacent scheme types bodies already operate, not body-accreditation standards — are collected in the context block below the table.
| Standard | Title (short) | What it accredits / defines | Verdict & reason |
|---|---|---|---|
| Band 1 The accreditation route — what the VVB needs chosen route first | |||
| ISO/IEC 17029:2019 + ISO 14065:2020 | V&V bodies (general) + V&V bodies for environmental information | Competence and impartiality of a body that validates or verifies environmental information and GHG statements; 14065 is the environmental specialisation of 17029 | Chosen route The accreditation the VVB must hold. ISO/IEC 17029 + ISO 14065 with ISO 14067 product scope, accredited by a national accreditation body under Regulation (EC) No 765/2008, with engagements conducted per ISO 14064-3. This does not mean re-verifying every rating: the provider's calculation system is validated once against ISO 14067 (CFP systematic approach), then sampled live claims are verified annually — the system is checked once and scales. Decisively, this is the route with real accredited suppliers: a register review of 8 July 2026 confirmed 18 bodies holding exactly this scope in the nine registers checked (16 DAkkS + 2 ACCREDIA: RINA, TÜV Italia; Certiquality a probable third; a lower bound — further EA registers not yet swept). See “Two routes”. |
| ISO/IEC 17065:2012 | Bodies certifying products, processes & services | Competence and impartiality of a body that certifies a product, process or service conforms to a scheme | Recital example — upgrade path No accredited LCA scope exists anywhere. Named in the directive's recital as one example of demonstrating third-party competence — but the 8 July 2026 register review found zero ISO/IEC 17065 accreditations with an LCA, product-carbon-footprint or rating scope in any of the nine registers checked. Anchoring EmpCo here would require a world-first accreditation of that scope. Documented instead as an optional future upgrade path: a 17065 certificate can later be added as a superstructure that reuses the accredited VVB's validation and verification statements as evaluation input, without repeating verification work (see docs/17065-upgrade-path.md). |
| Band 2 Standards the scheme relies on — but not what the VVB is accredited to references & companions; each row names its role | |||
| ISO/IEC 17011:2017 | Requirements for accreditation bodies | Competence, consistency and impartiality of the accreditation bodies (e.g. SAS, DAkkS, UKAS, COFRAC) that accredit conformity-assessment bodies | Supporting standard The recognition chain above the VVB. Independence is not self-asserted: it flows from a three-layer chain — a national accreditation body operating under ISO/IEC 17011 and Regulation (EC) No 765/2008 (e.g. DAkkS) accredits the VVB to ISO/IEC 17029 + ISO 14065 with ISO 14067 product scope, and that VVB validates and verifies under the EmpCo scheme. This chain is what makes an EmpCo validation statement, verification statement, and label licence internationally recognised and directive-defensible. |
| ISO/IEC 17067:2013 | Fundamentals of product certification & scheme types | Defines product-certification scheme types (1a–6) by the evaluation and surveillance activities they include; guidance for scheme owners | Supporting standard Scheme-type grammar (historical). The companion to ISO/IEC 17065 under which EmpCo v0.3.x was classified as a Type 6 process/service scheme. The current version is structured as a third-party verification scheme instead; 17067 is retained as context for the “check the system once, then scale” economics, which carry over unchanged. Not a body-accreditation standard. |
| ISO 19011:2018 | Guidelines for auditing management systems | Audit principles, programme management, auditor competence | Supporting standard General audit guidance. Referenced as background guidance for audit practice; under the verification architecture the engagement-level process is governed by ISO 14064-3. |
| ISO 14064-3:2019 | GHG statements — verification procedure | A procedure for validating and verifying greenhouse-gas statements (not a body-accreditation standard) | Supporting standard The engagement-level process standard of the chosen route. Governs how each validation and verification engagement is planned, evidenced, and concluded — materiality, evidence-gathering, level of assurance, statements. The confirmed accreditation scopes cite ISO 14067 in conjunction with ISO 14064-3. Companion to ISO 14065; the VVB is accredited to 17029 + 14065, and conducts engagements per this standard. |
| ISO 14046:2014 | Water footprint — principles & requirements | LCA-based method (on ISO 14040/14044) for assessing and reporting a product, process or organisation water footprint | Supporting standard Water-indicator method. EmpCo carries a water indicator, so 14046 is the recognised reference for how that figure is assessed and reported — including whether it is volumetric consumption or scarcity-weighted impact (the latter typically using the WULCA AWARE characterisation model, as in EU PEF). Cited as the methodology basis for the water metric, not as a body-accreditation standard. |
| ISO 14026:2017 | Communication of footprint information | Principles, requirements and verification for footprint communications and footprint communication programmes | Supporting standard Footprint-communication layer. Maps closely onto what EmpCo does — communicating a verified product footprint under a programme with third-party verification — sitting above a quantification standard (ISO 14067). Excludes the quantification itself. |
| ISO/IEC 17000:2020 | Conformity-assessment vocabulary | Defines validation, verification, certification, attestation, object of conformity assessment, owner | Supporting standard Shared vocabulary. Used to keep the scheme's use of those terms precise and consistent with the standards above. |
| Band 3 Considered and ruled out — and why reason leads each row | |||
| ISO/IEC 17025:2017 | Testing & calibration laboratories | Competence of a laboratory to produce a reliable measurement | Ruled out Lab measurement, not attestation. Accredits measurement competence, not conformity attestation. EmpCo attests that an assessment pathway conforms to a scheme, not that a lab produced a measurement. Appears only incidentally in the landscape survey as portfolio depth held by broad multi-discipline bodies. |
| ISO/IEC 17021-1:2015 | Management-system certification bodies | Bodies certifying management systems (e.g. ISO 9001 / 14001) | Ruled out Management-system certification — wrong anchor. EmpCo is not a management-system certification. Common in candidate bodies' portfolios but not the correct anchor for a product/process scheme. |
| ISO/IEC 17024:2012 (Ed.3 2026) | Certification of persons | Bodies that certify individuals against a competence scheme | Ruled out Certifies persons, not a system. Wrong object — EmpCo certifies an assessment system, not people. Noted only as the standard that would apply if EmpCo later credentialled its own assessors. A 2026 third edition has been published; the 2012 edition remains valid in transition. |
| ISO/IEC 17020:2012 (Ed.3 2026) | Inspection bodies | Bodies performing inspection (point-in-time examination) | Ruled out Inspection — only an on-site sub-activity. Seen on some bodies' portfolios; could govern an on-site sub-activity only, not the scheme's accreditation. A retitled 2026 third edition was published 27 March 2026 (transition to ~March 2029); the 2012 edition remains valid in transition. |
Neighbouring scheme & methodology standards
These define adjacent scheme types, the LCA / footprint methodologies under them, and the EU regulatory and food-sector context around them — they are not body-accreditation standards. ISO 14025 / 14024 / 14021 and ISO 14067 / 14040 / 14044 are the genre and quantification stack; EU EF 3.1 / PEF is the EU-context method EmpCo positions against; food-safety, traceability and corporate-reporting standards are acknowledged as orthogonal or downstream (EmpCo produces data they may consume). The scopes a body holds against these are the relevance signals used in the landscape survey below. Already in EmpCo normative or contextual references.
These adjacent scheme types, methodologies and regimes around EmpCo are the relevance signals used in the landscape survey below; the scopes a body holds against them indicate fit.
Two routes in the directive — and why verification was chosen
EU Directive 2024/825's operative text names no standard: it defines a “third-party verification scheme” and requires a third party whose competence and independence are “based on international, Union or national standards and procedures.” Only the non-binding recital gives examples — and it gives two, of equal rank: compliance with relevant international standards “such as ISO 17065”, or “the mechanisms provided for in Regulation (EC) No 765/2008” — the EU accreditation system itself. An accreditation to ISO/IEC 17029 under Regulation 765/2008 is that second route, not an approximation of it. ESFC weighed both and chose the route with real accredited suppliers.
Route A · Validation/verification Chosen route
- Standard: ISO/IEC 17029:2019 + ISO 14065:2020, with ISO 14067 product scope; engagements conducted per ISO 14064-3; accreditation via Regulation (EC) No 765/2008.
- What is attested: the provider's assessment pathway — its calculation methodology and system — is validated once against ISO 14067 (CFP systematic approach), concluded by a validation statement with defined validity conditions; sampled live market claims are then verified annually. Not per-claim re-verification: the system is checked once and scales.
- Market reality: a systematic register review of 8 July 2026 confirmed 18 bodies holding this exact scope in the nine registers checked — 16 DAkkS-accredited “Verifizierungsstellen” plus at least 2 ACCREDIA-accredited bodies (RINA VV 00005, TÜV Italia VV 00077; Certiquality VV 00027 a probable third). A lower bound: further EA-member registers were not swept.
- Why chosen: it is the recital's second demonstration route with real accredited suppliers today; a quantified footprint label is exactly the kind of environmental claim these bodies are accredited to validate and verify; and the scheme's economics (system checked once, sampled surveillance) carry over unchanged.
Route B · Certification Recital example — upgrade path
- Standard: ISO/IEC 17065:2012.
- What would be attested: a body certifies that the provider's assessment pathway conforms to the EmpCo scheme, with ratings as outputs of a certified system.
- Precedent: the model used by established food-and-environment programmes — MSC, Rainforest Alliance, Origin Green — in their domains. But for LCA-based ratings there is no precedent: the 8 July 2026 review of nine accreditation registers found zero ISO/IEC 17065 accreditations with an LCA, product-carbon-footprint or rating scope, in food or any other sector.
- Why not primary: anchoring on 17065 would make the scheme depend on a world-first accreditation of a scope no register contains. It is documented instead as an optional future upgrade path: a 17065 certificate added later as a superstructure that reuses the accredited VVB's statements as evaluation input (see docs/17065-upgrade-path.md).
How the process works under ISO/IEC 17029
Four instruments run the scheme: an accreditation for the VVB, a one-time validation statement and annual verification statements issued by the VVB, and one label licence per provider issued by the Certification Committee — traders derive their usage rights through the provider. The economics: validate the system once, verify sampled claims annually, tolerate defined drift, scale to many products and thousands of traders.
- 1 · Accredit
A national accreditation body accredits the VVB (Reg. 765/2008; at least 18 register-confirmed bodies hold the scope). - 2 · Validate once
The VVB — after confirming the scheme is consistent with its accreditation (ISO/IEC 17029 cl. 8) — validates the provider's calculation system (ISO 14067 Annex C.3.4): a validation statement with validity conditions. - 3 · License
The Certification Committee issues one 3-year label licence to the provider — acting only on the VVB's statements. No per-trader Committee act. - 4 · Claim in market
Traders derive usage rights through the provider — Standard (menus): automatically via the provider's terms (Annex G), recorded in the provider's trader register — status confirmed to anyone on request; Enhanced (on-pack): an Enhanced schedule in those terms, or an individual licence. Approved wording only (EmpCo-08); duty to furnish data on inquiry. - 5 · Verify annually
The VVB samples the claims traders actually communicate (100/200/200): input data, recalculation (±5%), rating, and claim wording — an annual verification statement. Complaints can trigger checks in between. - 6 · Evolve within limits
The system may change inside the materiality envelope; major changes trigger focused re-validation before deployment.
The design separates assessing from deciding — the one structural choice everything else follows from. (For readers familiar with ISO/IEC 17065: the certification body's two roles, evaluation and decision, are here held by two different organs.)
The VVB assesses
An accredited validation/verification body validates the calculation system once (a validation statement with validity conditions) and verifies sampled live claims each year (a verification statement). It issues statements — it does not grant, suspend, or withdraw anything.
The Certification Committee decides
A scheme organ issues, suspends, and withdraws the label licence — acting only on the VVB's statements and findings (a bright-line rule: no licence against a negative statement, no refusal against a positive one). It does not re-assess the science.
The split exists because a 17029 accreditation supplies only the directive's independent-third-party criterion. Open access, stakeholder-developed requirements, and suspension/withdrawal — which a 17065 body carried in its own accredited clauses — now live in the scheme's governance documents and are executed by the Committee.
The instruments
| Instrument | Issued by | What it does |
|---|---|---|
| Accreditation | National accreditation body (DAkkS et al.), under Reg. (EC) No 765/2008 | Attests the VVB's competence and impartiality for ISO/IEC 17029 + ISO 14065 validation/verification with ISO 14067 product scope; EU-wide recognition via EA peer evaluation. |
| Validation statement (with validity conditions) | VVB — once per pathway | Confirms the provider's calculation system is sound (ISO 14067 Annex C.3.4, engagement per ISO 14064-3). Its validity conditions are the change-management materiality envelope: the system may evolve inside them without re-validation. |
| Verification statement | VVB — annually | Confirms a sample of the claims traders actually communicate: input data, recalculation (±5%), rating, claim wording (EmpCo-08). |
| Label licence (3 years) | Certification Committee — one per provider | The right to operate under the scheme and carry the label; conditional on passing annual verification statements. Suspension and withdrawal are Committee decisions on VVB findings. |
| Trader usage rights | Provider — via its customer terms (Annex G: Enhanced schedule or individual agreement) | Derived right to display ratings: claim-wording rules, individually recorded acceptance, portal listing, duty to furnish information on inquiry. |
Calculation-drift thresholds — the licence's validity conditions
The numeric tolerances are recorded as the validity conditions of the validation statement: a change that stays inside them leaves the licence in force; one that exceeds them triggers a focused re-validation before deployment. Each pathway's exact figures are fixed by the VVB at validation. The scheme floor is:
- Materiality (change management): a change is material if it flips the rating for more than 2% of regression-suite items, or moves CO2eq/DFU by more than 10% for more than 5% of items.
- Per-claim recalculation tolerance: the VVB independently recalculates sampled claims against the evidence file; typical accepted variance ±5%.
- Discrepancy escalation: if more than 5% of a sample shows rating-changing discrepancies, the sample is expanded by 50% and the affected system components are re-validated; a systematic pattern triggers a category suspension by the Committee.
- Regression suite: at least 300 items across at least 3 input cases, run on every release — the statistical basis for the materiality calculation.
Multiple pathways — one floor, a declared variation surface
The scheme is deliberately methodology-neutral: many provider pathways can be licensed under one framework. A small uniformly-mandatory floor keeps ratings comparable and auditable (LCIA method EF 3.1, the A–E rating shape, cradle-to-grave boundary, evidence-file structure, change management). Above the floor, a pathway declares its own choices and the VVB assesses them at validation:
- Benchmark / reference dataset and A–E thresholds — each pathway publishes its own, with the derivation rationale. A different benchmark dataset is simply a different pathway.
- LCI background database (Agribalyse, Ecoinvent, or another), calculation engine, and gap-filling logic — declared with full freedom.
- Additional display units — a pathway may show per-kg, per-serving, or per-100 g alongside the rating.
Who can do this work today
The register review (8 July 2026) found an asymmetric market: at least 18 bodies hold the ISO/IEC 17029 + ISO 14065 accreditation with ISO 14067 product scope the scheme requires (16 DAkkS + 2 ACCREDIA; a lower bound — only nine EA registers were swept), while no ISO/IEC 17065 accreditation with an LCA, PCF or rating scope was found in any register checked. That asymmetry is why EmpCo anchors on the validation/verification route. One sharpening from reading all sixteen annex texts (9 July): the product-level scopes cover verification; the scheme's one-time validation engagement will typically need a scope extension — a known accreditation procedure (project-level validation is already accredited for most bodies), and the RFP asks each bidder for its route. Register scopes are snapshots — re-verified before any eligibility decision; no body is named or endorsed here, and the VVB will be appointed on its own merits. A broader June 2026 desk survey (~220 organisations) preceded this review and is retained as provenance below.
If you are a validation/verification body
ESFC is the scheme owner, not an accreditation expert, and has not appointed a validation/verification body. We set out below the accreditation the scheme is built on and invite any interested accredited body to review the VVB requirements and get in touch. We do not pre-judge any body's eligibility — that is for the body and its accreditation registry to determine.
Two findings from the research above frame why the scheme may be worth a body's attention. From 27 September 2026, EU Directive 2024/825 restricts generic environmental claims across the EU, making a publicly accessible, third-party-verified scheme the principal route to compliant on-product claims. And the 8 July 2026 register review shows that the accredited capacity for exactly this work already exists: at least 18 bodies hold ISO/IEC 17029 + ISO 14065 accreditation with ISO 14067 product scope (confirmed in nine registers; further EA registers not yet swept). EmpCo is a published, methodology-neutral scheme sitting in that gap — and the body that validates and verifies under it has not yet been appointed.
EmpCo is anchored on ISO/IEC 17029:2019 + ISO 14065:2020 with ISO 14067 product scope, accredited under Regulation (EC) No 765/2008, with engagements conducted per ISO 14064-3: the VVB validates that a provider's assessment pathway — its calculation methodology and system — conforms to the scheme's requirements, and verifies sampled live claims annually. That is the accreditation the appointed VVB is expected to hold. If your body is one of the at least 18 confirmed holding this scope — or holds an equivalent accreditation under another Regulation 765/2008 national accreditation body — you already hold the core accreditation the scheme requires — the annual verification engagement is deliverable under it as-is; for the one-time system validation, the RFP asks how you would cover it (product-scope extension or an alternative accredited structuring).
Bodies accredited under ISO/IEC 17065:2012 operate the neighbouring certification route named as an example in the directive's recital. Because no 17065 accreditation with an LCA scope exists in any register checked, that route is documented as an optional future upgrade path rather than a current requirement (see “Two routes” above) — a 17065-accredited body could become relevant to EmpCo later, as the superstructure that reuses the VVB's statements.
Whether a given body's accreditation scope fits EmpCo is a question for that body and its national accreditation registry, against the live scheme requirements — not something ESFC determines from the outside. If you would like to explore the fit, the VVB requirements are the right place to start.
How to express interest
- Review VVB-01 (VVB Requirements) and VVB-02 (Engagement Team Competencies) — they set the mandatory accreditation, independence, and competence requirements.
- Review VVB-03 (Engagement Methodology Companion), an informative companion describing how validation and verification engagements under the scheme are planned, evidenced, and concluded per ISO 14064-3.
- Check the accreditation and scope requirements in VVB-01 §2 against your current accreditation certificate and scope annex.
- Express interest to ESFC using the button below.
What this research changed
Each design decision on this page is traceable to a scheme version and its documents. This ties the rationale above to the published record.
| Finding / decision | Scheme version | Where it lives |
|---|---|---|
| ISO/IEC 17065 adopted as the mandatory CB accreditation standard (system-certification model) | v0.1.0 – v0.3.x (superseded in v0.4.0-draft-vv) | Historical scheme versions (repository history) |
| CB-03 reframed as an informative companion — the assessing body defines its own evaluation procedure | v0.3.7-draft (superseded — VVB-03 engagement-methodology companion in v0.4.0-draft-vv) | VVB-03 (verification-body/, companion) |
| ISO/IEC 17029 + ISO 14065 documented as the verification-route runner-up; recognition under consideration | v0.3.7-draft (superseded — adopted as the chosen route in v0.4.0-draft-vv) | This page (earlier revision) |
| EmpCo classified as an ISO/IEC 17067 Type 6 scheme — certification of a process/service (the provider's assessment pathway) with ongoing surveillance, not per-product certification | v0.3.8-draft (restructured as a third-party verification scheme in v0.4.0-draft-vv) | EmpCo-02 §2.5.6 (scheme classification note) |
| Certification-body landscape survey (13 streams; ~220 → ~160 → ~62; 5 relevance categories) | Desk research, 3 June 2026 | This page (desk-research, unverified) |
| Systematic accreditation-register review: zero ISO/IEC 17065 accreditations with an LCA/PCF/rating scope in the nine registers checked; 18 bodies (16 DAkkS + 2 ACCREDIA: RINA, TÜV Italia; Certiquality a probable third) hold ISO/IEC 17029 + ISO 14065 with ISO 14067 product scope | Register review, 8 July 2026 | Decision basis for v0.4.0-draft-vv; docs/vv-architecture-blueprint.md |
| Scheme rebuilt on ISO/IEC 17029 + ISO 14065 (ISO 14067 product scope; engagements per ISO 14064-3): the VVB validates the pathway once and verifies sampled claims annually; label licences issued by the scheme's Certification Committee on the VVB's statements | v0.4.0-draft-vv | EmpCo-02 §2.4.3–§2.5; VVB-01–03 (verification-body/); docs/vv-architecture-blueprint.md |
| ISO/IEC 17065 documented as an optional future upgrade path — a certificate layered later over the accredited VVB's statements, not the primary route | v0.4.0-draft-vv | EmpCo-02 §2.5 (non-normative note); docs/17065-upgrade-path.md |
| EU-directive and German-transposition citations verified against primary sources (Art. 2 points (q)/(r), Annex I point 2a, recital 7; BGBl. 2026 I Nr. 43) | Verification pass, 9 July 2026 | docs/legal-foundation-requests.md, Appendix A (not legal advice; recital and FAQ non-binding) |
| ISO texts purchased and read — ISO 14067 Annex C §C.3.4 confirmed as the system-validation reference; ISO 14064-3 assurance levels grounded (final level to be fixed with the contracted VVB) | 9 July 2026 | EmpCo-02 §2.2.3, EmpCo-VVB-01/-03 (licensed texts held privately; only clause references published) |
| "Climate-friendly" formalised as a defined rating term bound to the A rating; generic-term blacklist expanded (construct put to the legal opinion) | 9 July 2026 (supersedes MR !1) | EmpCo-08 §8.3.1, §8.4 |