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UPPS Standard

Universal Product Passport Standards (UPPS)

Version 1.0

Effective: May 2026

UPPS 201: Environmental Product Disclosures

Establishes disclosure requirements for environmental characteristics and impacts of products under the Universal Product Passport Standards (UPPS).

UPPS 201 defines the disclosure requirements for environmental information that organizations shall provide to ensure transparency of product environmental impacts.

[NORMATIVE]

Sections 1-10 contain normative requirements that shall be followed for UPPS compliance. Guidance sections provide non-binding recommendations.

1

Introduction

UPPS 201 establishes disclosure requirements relating to the environmental characteristics and impacts of products.

This Standard defines the disclosures necessary to enable consistent, comparable, and decision-useful information regarding the environmental performance of products across their lifecycle.

Environmental information is a critical component of product-level transparency. Increasing regulatory requirements, market expectations, and sustainability objectives require organizations to disclose information on environmental impacts associated with products, including emissions, resource use, and waste.

UPPS 201 provides a structured framework for such disclosures, enabling alignment across jurisdictions and supporting regulatory implementation, including compatibility with frameworks such as the European Union's Ecodesign for Sustainable Products Regulation (ESPR).

2

Objective

The objective of UPPS 201 is to ensure that organizations disclose environmental information that enables users to:

  • Understand the environmental impacts associated with a product across its lifecycle
  • Compare environmental performance across products and organizations
  • Assess environmental risks, efficiencies, and improvement opportunities
  • Support regulatory compliance and sustainability-related decision-making

UPPS 201 establishes consistent requirements for environmental product disclosures that support transparency and comparability.

3

Scope

UPPS 201 applies to all products for which environmental information is disclosed under UPPS.

Organizations shall apply this Standard in conjunction with UPPS 101.

Environmental disclosures shall reflect the lifecycle of the product, including:

  • Upstream activities (e.g., material extraction and processing)
  • Manufacturing and assembly
  • Distribution and logistics
  • Use phase
  • End-of-life

Where lifecycle coverage is partial, organizations shall disclose the boundaries and limitations.

4

General Requirements

4.1Basis of Measurement

Organizations shall disclose the methodologies used to quantify environmental information.

Where applicable, disclosures shall be based on recognized methodologies, including lifecycle assessment (LCA) approaches.

Where estimates are used, organizations shall disclose the assumptions and limitations.

4.2Boundaries and Coverage

Organizations shall clearly define:

  • Lifecycle stages included in the disclosure
  • Organizational boundaries
  • Data coverage and exclusions

4.3Units and Metrics

Environmental disclosures shall be presented using appropriate and standardized units.

Examples include:

  • Greenhouse gas emissions (kg CO₂e)
  • Energy use (kWh or MJ)
  • Water use (liters or cubic meters)
  • Waste (kg)

4.4Data Quality and Verification

Organizations shall disclose:

  • Data sources (measured, estimated, modeled, supplier-provided)
  • Level of verification, if applicable

Where data is modeled or estimated, the level of uncertainty shall be disclosed.

5

Environmental Product Disclosures

Organizations shall disclose the following environmental information for each product.

5.1Greenhouse Gas EmissionsUPPS 201.5.1

Disclosure Requirement

Organizations shall disclose greenhouse gas (GHG) emissions associated with the product.

Required Disclosures

  • Total lifecycle GHG emissions (kg CO₂e per product)
  • Emissions by lifecycle stage, where available
  • Methodology used for calculation

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

GHG emissions disclosures should align with recognized carbon accounting standards such as ISO 14067 (Carbon Footprint of Products), PAS 2050, or the GHG Protocol Product Life Cycle Accounting and Reporting Standard. Organizations should specify which methodology was applied and document any deviations from standard approaches.

Lifecycle emissions should cover raw material extraction, manufacturing, transportation, use phase, and end-of-life treatment. Where complete lifecycle data is unavailable, organizations should disclose the scope of assessment (e.g., cradle-to-gate, cradle-to-grave) and identify excluded stages with justification. Primary data should be used where available; secondary data sources should be documented.

Emissions should be reported in kg CO₂e per functional unit, with the functional unit clearly defined. All greenhouse gases covered by the Kyoto Protocol should be included and converted to CO₂ equivalents using IPCC global warming potential factors. Organizations should specify the GWP timeframe used (e.g., 100-year GWP).

5.2Energy ConsumptionUPPS 201.5.2

Disclosure Requirement

Organizations shall disclose energy consumption associated with the product.

Required Disclosures

  • Total energy use across lifecycle stages
  • Energy use during manufacturing
  • Energy use during product use phase, where applicable

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

Energy consumption should be reported in standard units (MJ, kWh, or GJ) across all lifecycle stages. Organizations should distinguish between renewable and non-renewable energy sources, and specify the energy mix where relevant to environmental impact assessment.

Manufacturing energy should include both direct energy consumption in production facilities and indirect energy embedded in purchased materials and components. For products with significant use-phase energy consumption (e.g., appliances, vehicles), organizations should provide estimated annual or lifetime energy use based on standard usage patterns.

Energy efficiency metrics should be provided where applicable, such as energy per unit of output, energy intensity ratios, or compliance with energy efficiency standards (e.g., Energy Star, EU Energy Label). Organizations should document assumptions about usage patterns, operating conditions, and product lifetime used in energy calculations.

5.3Water UseUPPS 201.5.3

Disclosure Requirement

Organizations shall disclose water consumption associated with the product.

Required Disclosures

  • Total water use across lifecycle stages
  • Water use during manufacturing
  • Water intensity, where applicable

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

Water use disclosures should distinguish between water withdrawal (total water taken from sources) and water consumption (water not returned to the source). Organizations should report both metrics in cubic meters (m³) or liters, specifying the measurement approach and boundaries.

Water stress context is critical. Organizations should identify whether water is sourced from water-stressed regions using tools such as the WRI Aqueduct Water Risk Atlas or WWF Water Risk Filter. Water use in high-stress regions should be separately disclosed and contextualized.

Water quality impacts should be considered alongside quantity. Organizations should disclose wastewater generation, treatment methods, and discharge quality where material to environmental impact. Water use efficiency metrics and recycling rates should be provided where applicable.

5.4Waste GenerationUPPS 201.5.4

Disclosure Requirement

Organizations shall disclose waste generated across the lifecycle of the product.

Required Disclosures

  • Total waste generated
  • Waste by type (hazardous, non-hazardous)
  • Waste generated during manufacturing and end-of-life

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

Waste generation should be reported by type (hazardous, non-hazardous) and by disposal method (recycled, incinerated, landfilled). Organizations should follow waste classification systems aligned with local regulations (e.g., EU Waste Framework Directive, Basel Convention for hazardous waste).

Manufacturing waste should include production scrap, defective products, and packaging waste. Organizations should report waste intensity metrics (waste per unit of production) and waste diversion rates (percentage of waste diverted from landfill through recycling, composting, or energy recovery).

End-of-life waste projections should be provided where the product itself becomes waste. This includes estimated product weight at disposal, material composition affecting recyclability, and expected disposal pathways based on available infrastructure and product design.

5.5Use of Recycled and Renewable MaterialsUPPS 201.5.5

Disclosure Requirement

Organizations shall disclose the extent to which recycled or renewable materials are used in the product.

Required Disclosures

  • Percentage of recycled materials
  • Percentage of renewable materials
  • Types of recycled or renewable inputs

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

Recycled content should be reported as percentage by weight, distinguishing between pre-consumer (post-industrial) and post-consumer recycled materials. Organizations should specify the types of recycled materials used and provide third-party certification where available (e.g., GRS - Global Recycled Standard).

Renewable materials should be defined as materials derived from biological resources that can be replenished within a human timescale. Organizations should disclose the percentage of renewable content by weight and specify material types (e.g., bio-based plastics, sustainably sourced wood, natural fibers).

Sustainability certifications for renewable materials should be disclosed (e.g., FSC for wood, USDA BioPreferred, RSB for bio-based materials). Organizations should document the methodology used to calculate recycled and renewable content percentages, including allocation approaches for multi-material products.

5.6Hazardous Substances and Environmental ImpactUPPS 201.5.6

Disclosure Requirement

Organizations shall disclose the presence of substances that may pose environmental risks.

Required Disclosures

  • Presence of regulated hazardous substances
  • Relevant thresholds or concentrations, where applicable
  • Compliance with applicable substance regulations

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

Hazardous substance disclosures should align with applicable regulations such as REACH (EU), RoHS (Restriction of Hazardous Substances), California Proposition 65, or equivalent regional frameworks. Organizations should identify substances of concern by chemical name and CAS number where applicable.

Threshold reporting should follow regulatory requirements. For substances above regulatory thresholds, organizations should disclose concentration levels, location within the product, and function of the substance. Compliance statements should reference specific regulations and testing methods used.

Organizations should disclose efforts to substitute hazardous substances with safer alternatives, including timelines for phase-out where applicable. Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) should be referenced or made available for products containing hazardous materials.

5.7End-of-Life Environmental ImpactUPPS 201.5.7

Disclosure Requirement

Organizations shall disclose environmental considerations associated with end-of-life treatment of the product.

Required Disclosures

  • Recyclability of the product
  • Recovery potential
  • Expected disposal pathways

Guidance

[INFORMATIVE]

The following guidance provides non-binding recommendations for implementation.

End-of-life environmental impact assessments should consider the full range of disposal scenarios, including recycling, energy recovery, composting, and landfilling. Organizations should provide data on the environmental preferability of different disposal pathways based on lifecycle assessment.

Recyclability should be assessed based on actual recycling infrastructure availability, not theoretical recyclability. Organizations should specify geographic regions where recycling infrastructure exists and provide guidance on proper disposal. Material compatibility with existing recycling streams should be documented.

Recovery potential should quantify the percentage of product mass that can be recovered through recycling or energy recovery. Organizations should disclose design features that facilitate or hinder end-of-life processing, such as material separability, use of adhesives, or presence of composite materials. Environmental impacts of different end-of-life scenarios should be quantified where data is available.

6

Presentation of Information

Organizations shall present environmental disclosures in a manner that is:

  • Clear and understandable
  • Comparable across products and reporting periods
  • Consistent with UPPS 101

Where appropriate, disclosures may be integrated into digital product passports.

Environmental disclosures shall be presented in a way that allows users to understand both absolute impacts and relative performance.

7

Effective Date

UPPS 201 is effective for disclosures published after [To be determined].

Early adoption is permitted.

8

Relationship with Other UPPS Standards

UPPS 201 shall be applied together with:

  • UPPS 101 — General Product Disclosures
  • Future UPPS standards on circularity and supply chain traceability
  • Industry-specific UPPS standards
9

Transition Provisions

Organizations may adopt UPPS 201 progressively.

Where full lifecycle data is not available, organizations shall disclose:

  • The scope of available data
  • Data gaps and limitations
  • A plan for improving coverage over time
10

Regulatory Alignment

UPPS 201 is designed to support alignment with environmental disclosure requirements across jurisdictions.

This includes compatibility with regulatory frameworks such as:

  • Ecodesign for Sustainable Products Regulation (ESPR)
  • Other national and regional environmental disclosure requirements

UPPS 201 enables organizations to structure environmental disclosures in a manner that can be mapped to multiple regulatory frameworks, reducing duplication and improving consistency.

Compliance Checklist

[INFORMATIVE]

This checklist provides a summary of key compliance requirements for UPPS 201. Refer to the normative sections above for complete requirements.

Greenhouse Gas Emissions (UPPS 201.5.1)

  • Disclose total lifecycle GHG emissions (kg CO₂e per product)
  • Disclose emissions by lifecycle stage, where available
  • Disclose methodology used for calculation
  • Use recognized carbon accounting standards (ISO 14067, PAS 2050, GHG Protocol)

Energy Consumption (UPPS 201.5.2)

  • Disclose total energy use across lifecycle stages
  • Disclose energy use during manufacturing
  • Disclose energy use during product use phase, where applicable
  • Distinguish between renewable and non-renewable energy sources

Water Use (UPPS 201.5.3)

  • Disclose total water use across lifecycle stages
  • Disclose water use during manufacturing
  • Disclose water intensity, where applicable
  • Distinguish between water withdrawal and consumption

Waste Generation (UPPS 201.5.4)

  • Disclose total waste generated
  • Disclose waste by type (hazardous, non-hazardous)
  • Disclose waste generated during manufacturing and end-of-life

Recycled/Renewable Materials (UPPS 201.5.5)

  • Disclose percentage of recycled materials
  • Disclose percentage of renewable materials
  • Disclose types of recycled or renewable inputs

Hazardous Substances (UPPS 201.5.6)

  • Disclose presence of regulated hazardous substances
  • Disclose relevant thresholds or concentrations, where applicable
  • Disclose compliance with applicable substance regulations

End-of-Life Environmental Impact (UPPS 201.5.7)

  • Disclose recyclability of the product
  • Disclose recovery potential
  • Disclose expected disposal pathways