Do EPDs for France have to be on INIES?

5 min read
Published: November 29, 2025

Short answer: not legally for every product, but practically yes if you want your product‑specific impacts to count in French RE2020 building LCAs. If your data isn’t on INIES, modelers default to generic values that are conservative by design, which can quietly push you out of a spec.

A stylized highway on‑ramp labeled with a small INIES icon, merging cleanly into a bright city skyline. Side roads labeled “generic defaults” appear congested, visually showing the advantage of being on the main route.

INIES and RE2020 in a nutshell

INIES is France’s national database for product environmental data used in building LCAs under RE2020. You are not forced by law to publish an EPD for every product. Yet to have product‑specific impacts used in the regulatory calculation, design teams rely on what’s available inside INIES at the time of simulation. If your product isn’t there, they use generic defaults.

What “being on INIES” actually means

For construction products, the accepted format is an FDES, France’s flavor of an EN 15804 EPD that also carries required health information. For building equipment, it’s a PEP. FDES and PEP are third‑party verified, published in INIES, and then pulled directly by the tools architects and LCA modelers use. FDES are valid for five years (INIES, 2025).

The numbers behind the pull

INIES isn’t a boutique registry. As of November 23, 2025, it lists 5,384 FDES and 1,738 PEP, representing 308,445 commercial references used by practitioners across France (INIES, 2025). (INIES, 2025)

Already have a European EPD? Here’s the catch

If your EPD was built for another program, it may still need alignment with EN 15804+A2 and France’s national complement before it can appear as an FDES in INIES. France is completing the transition from A1 to A2. From January 1, 2026, only A2‑format FDES remain active in INIES, with A1 archived and unusable for RE2020 workflows (Cerema, 2024). (Cerema, 2024)

Why it matters commercially

In RE2020 projects, the LCA is part of the permit and completion process. When your product’s specific data sits inside INIES, the team can model it accurately, which makes your spec defensible on both performance and carbon. If they have to fall back to generic defaults, your product can look heavier than it is, and competitors visible in INIES get the easy win. That is lost revenue you never see.

What teams that move fast typically do

  • Map SKUs to priority PCRs and confirm EN 15804+A2/CN alignment.
  • Collect a clean, auditable data pack for the latest 12‑month reference period.
  • Run the LCA to A2 rules, including French complements where required.
  • Get third‑party verification and publish to INIES, plus keep your pan‑EU visibility via ECO Platform where useful.
  • Calendarize renewals so nothing expires near critical bids.

A note on timing and continuity

RE2020 thresholds tighten over time. Keeping your FDES current in INIES avoids last‑minute scrambles and protects your spec position as rules evolve. Dont wait until a bid drops to discover a missing FDES. If you operate multiple plants or product configurations, plan for configurators or a portfolio approach so updates remain painless.

Bottom line

Publishing on INIES is the on‑ramp to being modeled as you are, not as a pessimistic stand‑in. If France is on your roadmap, treat INIES as a primary sales channel disguised as a database. The moment your data appears there, your sales team stops arguing carbon by proxy and starts winning on proof.

Frequently Asked Questions

Is it legally mandatory to publish every product’s EPD on INIES in France?

No. But to have product‑specific impacts used in RE2020 building LCAs, practitioners use what’s in INIES at simulation time. Without an INIES record, generic defaults are used instead.

Which format is accepted on INIES for construction products and equipment?

FDES for construction products and PEP for equipment. Both follow EN 15804 rules and French complements, are verified, and then published in INIES. FDES are valid for five years (INIES, 2025).

We already have an EPD with another European operator. Can it be used in France?

Often yes, after alignment with EN 15804+A2 and the French national complement and after verification, then publication on INIES as an FDES. From January 1, 2026, only A2‑format FDES are active in INIES (Cerema, 2024). (Cerema, 2024)

How large is INIES today and why should we care?

It’s widely used. On November 23, 2025, INIES listed 5,384 FDES and 1,738 PEP, covering 308,445 commercial references, which means your customers are likely modeling with it (INIES, 2025). (INIES, 2025)

Do EPDs for France have to be on INIES? | EPD Guide