SuMPO Environmental Labeling Program Announces New Fees for EPD 2024

Online Briefing Session Archives and Q&A

SuMPO Environmental Labeling Program Announces New Fees for EPD 2024 – Revamped Fees Take LCA Disclosure to Next Phase –

The Sustainable Management Promotion Organization (SuMPO; Chiyoda-ku, Tokyo; President: Takehisa Kabeya; hereinafter referred to as “SuMPO”) (SuMPO), in order to promote the spread of EPD (Environmental Product Declaration)*1, which is comprehensive product environmental information including carbon footprint, and to accelerate communication of environmental information among companies in the supply chain, starting in April 2024, SuMPO The fee for the SuMPO Environmental Labeling Program will be revised.

■News Release

■November 14, 2023 Briefing Archived on YouTube (SuMPO channel)
https://youtu.be/khHwhZ494tw

■Application Form for Information Session Materials
If you apply using the form, we will send you the URL for downloading the materials.
https://ws.formzu.net/fgen/S95804369/

Q&A Summary

[General]

Q1. We are currently preparing for the application, but is there any problem with applying and verifying in FY2023 (old fee) and then opening registration (EPD program membership) to the public in April 2024 with the new fee?
A1. No problem. Please note that an application for registration and release must be submitted within 3 months after passing the verification (notification of verification number).

Q2. I understand that a franchise fee will be introduced instead of a registration and publication fee, but am I correct in assuming that the fee will be a flat fee based on the size of the company, no matter how many EPDs are obtained during the year?
A2. The EPD Program affiliation fee is a flat fee based on the size of the company as defined by the SME Basic Law, regardless of the number of registered public declarations [1].

[1] Based on the Small and Medium Enterprise Basic Act, businesses are classified as small-scale enterprises, small and medium-sized enterprises, and large enterprises (including “deemed large enterprises”). Businesses that fall into the category of “deemed large companies” are defined by the “Subsidy for Promotion of Productivity Improvement in Manufacturing, Commerce and Services” of the Small and Medium Enterprise Agency of the Ministry of Economy, Trade and Industry (METI).
1. SMEs in which “more than 1/2 of the total number of issued shares or the total value of capital contribution is owned by the same large company
2. SMEs in which “more than 2/3 of the total number of issued shares or the total value of capital contribution is owned by large companies
3. Small and medium-sized enterprises where “persons who are also directors or employees of large enterprises” account for more than 1/2 of the total number of directors.
4. SMEs whose “total” number of issued shares or “total” capital contribution price is owned by SMEs falling under 1. through 3.
Small and medium-sized enterprises (SMEs) in which “all of the total number of directors and employees” are also directors or employees of SMEs that fall under 5.1. through 5.3.

Q3. If the EPD program affiliation fee is per company, is it correct that if an additional EPD is obtained from the current one, there will be no previous registration and publication fee and the only annual cost will be the EPD program affiliation fee?
A3. After the transition to the new fees, there will no longer be a registration and disclosure fee, and the only annual fee will be the EPD program affiliation fee. However, verification fees, calculation tool rental fees, and other fees will be charged separately.

Q4. The current registered public fee is for the calendar year, but what is the fee for the first January through March when the EPD program affiliation fee switches to the fiscal year?
A4. 25% of the current registration and publication fee (calculated on an annual sales basis) will be charged.

Q5. Why did you lower the registration and publication fee (EPD program affiliation fee)?
A5. We have revised our fee structure to further promote the disclosure of reliable and transparent product environmental information in Japan and to support communication of product environmental information that can be used globally. It is anticipated that reliable environmental information on their products using primary data will be required in many more situations in the future. We have revised the fee structure to promote reliable environmental information disclosure throughout the product lifecycle with the participation of many businesses.
In addition, since the affiliation fee is per company regardless of the number of EPDs registered and published, one of our objectives is to promote company-wide efforts to register and publish EPDs.

Q6.If a single business has multiple registrations, do all registration publication fees (EPD program affiliation fees) need to be transferred at the same time, or can they be transferred individually?
A6. The EPD Program affiliation fee is a flat fee based on the size of the company as defined by the SME Basic Law, regardless of the number of registered public declarations, and cannot be transferred separately for each declaration.

Q7. Currently, the validity period of verification is 5 years. If we do not pay the EPD program affiliation fee, does this mean that declarations registered and released in FY2023 will not be released in FY2026 and beyond?
A7. Failure to pay the EPD Program affiliation fee will invalidate all declarations at that time, even if the validity of the verification remains. Publication on the program website will be suspended and you will no longer be able to disclose or communicate using the declaration.

Q8. We plan to obtain EcoLeaf certifications for multiple products in the future. If we obtain the first certification in FY2023 (per-declaration fee applies) and obtain the second and subsequent certifications in FY2024, will the current fee for the second registration and publication be the same as the current fee?
A8. If you publish your declaration by the end of March 2024, you are an existing business and can choose to pay the existing registration and publication fee during the transition period.

Q9. Regarding the EPD affiliation fee, does it mean that a large company needs 1,000,000 yen/year even if it only registers one product?
A9. The EPD Program affiliation fee is flat based on the size of the company as defined by the SME Basic Law, regardless of the number of registered public declarations, so for large companies, the fee is 1,000,000 yen/year, whether the company registers one product or 100 products.

Q10. What happens when EPD program affiliation is done by an organization (industrial association)?
A10. For organizations (industrial associations, etc.), the EPD program affiliation fee is 400,000 yen/year.

Q11. If I pay the EPD program affiliation fee, is there no registration fee for the Climate declaration, or do I need to pay an additional 10,000 yen/declaration?
A11. Regardless of the EPD Program affiliation fee payment, a separate Climate declaration registration fee of 10,000 yen per declaration is required.

Q12. Is the EPD program affiliation fee due at the time of application or at the time of registration release?
A12. The EPD Program affiliation fee is due at the time the declaration is published.

[About verification fees]

Q13. In IDEA v.3.1, the intensity is subdivided and the number of flows is expected to increase. To what extent does the number of flows affect the verification?
A13. If the units of production are subdivided, it is necessary to verify in detail whether the units of production are selected appropriately, and the man-hours required for verification will increase by the number of flows.

Q14. If the fee varies depending on the number of flows, should we not fill in the amount of activity with zero data?
A14. If the information about the amount of zero activity is not related to the calculation, regulations, PCR, etc. at all, it is not necessary to fill in the form, but if the information is necessary for verification, it must be filled in.

Q15. When weighting data from multiple establishments, is it correct to understand that the number of flows x number of establishments is the weighted average?
A15. If the number of flows between multiple offices are all the same, then as you understand, the number of flows x number of offices will be used to determine the classification of the verification fee.

Q16. Will the registration publication fee by declaration unit be abolished? (100,000 yen/declaration/year)
A16. It will be discontinued after the transition to the new rates.

Q17. Are flow counts calculated by the Secretariat?
A17. Specific operations are under consideration, but the final decision will be made by the verifier.

Q18. It is expected that the number of flows is often not determined when estimating verification costs.
A18. As with the current situation, the price quoted may vary depending on the number of man-hours required during the verification process, but it is possible to quote a price based on preliminary information.

Q19. What are averages and variations?
A19. Within the broad framework of averages, the additional fee for variations is applied to average EPDs that consist of products from multiple organizations or companies, or to average EPDs from a single organization with significant differences in the data collection method, calculation method, etc. from which the average is derived.

Q20. Is the verification fee half the price of the first one after the second one, regardless of the number of cases, for similar products?
A20. For the second and subsequent verification fees for similar products, regardless of the number of cases (even after the 5th or 10th case), half of the fee for the first case will be added.

Q21. I understand that similar products will be half the price of the first verification fee, but are there any criteria to be considered similar products?
A21. No change from the current system. If you submit the “Similar Product Check Sheet” and the verifier recognizes the similarity, the second and subsequent half of the fee will be applied as a similar product.
https://ecoleaf-label.jp/resource/temp/（FB-03-05 Similar Products Check Sheet）

[Others]

Q22. Will the consulting service fee be revised?
A22. For consultation fees, please contact the LCA Expert Center, a separate department.
https://sumpo.or.jp/consulting/lca/

Q23. Will the system certification audit fee change when requesting a system certification audit to the Secretariat?
A23. System certification audit fees are under consideration with changes in mind.

Q24. I would like to know about the Climate declaration fee.
A24. Starting in FY2024, you will first obtain an EPD with a multidisciplinary evaluation as part of the standardization of EPDs. Then, you can optionally create a declaration that isolates only climate change, and the various fees for this are the Climate Declaration Fees.

Q25. Regarding EPD standardization, we have been making CFP declarations, but will there be any changes in the calculation process when it becomes EPD?
A25. Depending on the PCR, there will be no change in the basic collected data or calculation methods. In addition, no major revision of PCRs is planned for EPD standardization.

Q26. I understand that you are launching a new website, but will CFP declarations obtained in the past continue to be accessible?
A26. You will continue to have access to the site during the validity period of the verification.

Q27. Regarding the introduction of the new logo, how will it be handled if the logo is used on a product acquired in the past?
A27. A transition period will be provided so that the current logo can be used for at least one year after the introduction of the new logo.

*All prices exclude tax.