ISO 59040 is the international standard that defines the product circularity data sheet, one fixed form a supplier fills in so a buyer gets the same circularity facts about every product they buy.
Think of the safety data sheet that comes with a chemical. Same idea of one form everyone completes the same way, except this one answers how circular a product is. ISO 59040 was published in 2025.
A product circularity data sheet is not a label for shoppers and it is not a marketing asset. It is a business document, written by the company that supplies a product for the company that buys it.
ISO 59040 in short
Here are the details most people come looking for.
- Standard ISO 59040
- Full title Circular economy, product circularity data sheet
- Current edition 2025, the first edition
- Status Published
- Type Requirements and guidance, not a certification
- Published by ISO/TC 323, the ISO committee for the circular economy
- Family The ISO 59000 family of circular economy standards
What a product circularity data sheet is
A product circularity data sheet, usually shortened to PCDS, is a product declaration that presents standardised information about how circular a product is, in a form other people can use to judge it for themselves.
Three things get called "the PCDS" in conversation, and ISO 59040 keeps them apart.
- The template is the blank form. It sets out which statements appear, in what order, under what numbering.
- A statement is one line on that form describing a circularity fact about the product. Each one is answered True or False.
- The PCDS is the completed form, filled in by a supplier for one specific product.
The standard is deliberately strict about the shape of the form. The order of the categories, the numbering, the wording of the statements and the two-state answers are all fixed. That is the point.
A sheet from one supplier lines up with a sheet from another, and software can read both without anyone rekeying anything.
How a True or False statement protects a trade secret
This is the part of ISO 59040 that does the real work, so it is worth slowing down on. Three things hold it together. The answers are limited, they have to be provable, and the checking is agreed between the two companies rather than handed to an outside body.
Two possible answers and nothing else
Every statement on a PCDS is answered True or False. There is no free text box and no figure to hand over.
Take recycled content. A buyer needs to know whether a component clears the threshold they are working to. The supplier would rather not publish the exact percentage, the grade, or the name of the company they buy the material from.
Marking the statement True gives the buyer the fact they need and leaves the commercial detail with the supplier.
Every True has to be provable
Two possible answers on their own would just be a tick box. The standard also requires each statement to be verifiable.
A True answer is a claim the supplier has to be able to stand behind with real evidence, so the sheet is not a place to be optimistic.
What makes a sheet conform and who checks it
Two rules decide when a completed sheet actually counts as conforming to the standard.
- Every mandatory statement has to be answered. A supplier can only claim their sheet conforms to ISO 59040 once every mandatory statement on the template carries an answer.
- Additional statements are optional. A template can also hold extra statements and supplementary information. A supplier can leave those blank and still conform.
ISO 59040 is not a certification. There is no certificate and no accredited scheme behind it.
Instead the buyer and the supplier agree in advance how the sheet gets checked. The standard lets that conformity assessment be done by the supplier themselves, by the buyer, or by an authorised third party, through a process audit, a verification of the statements, or both together.
The seven categories inside a PCDS
A PCDS template is organised into seven numbered categories, and each category breaks down further into modules. Because the numbering is fixed by the standard, the same kind of fact always sits in the same place on every sheet.
| Category | What it covers |
|---|---|
| PCDS template | Who issued the template, its identifier and version, and the permanent address it lives at |
| Company and product information | Which product this is, who supplies it, which site made it, and when the sheet was issued or last revised |
| Material inputs | What the product is made of, hazardous substances and substances of concern, reused content, recycled materials and renewable materials |
| Circular production | Renewable energy used in production, and water reuse or recirculation |
| Durability and extended lifetime | Reliability, maintenance and repair, upgradability, demounting, disassembly, reuse and refurbishing |
| Circularity at end of product use period | Any part of the product released into the environment while it is in use, plus dismantling, remanufacturing, recycling, composting and biodegradability |
| Circularity benefits | Environmental benefits |
Demounting, disassembly and dismantling sound like the same thing and are not, so the standard defines each one separately.
- Demounting is taking a product out of whatever it was fitted into, without damaging it.
- Disassembly is taking a product apart in a way that lets it be put back together and used again.
- Dismantling is taking it apart with no intention of reassembling it, though parts can still be reused afterwards.
The material inputs category is the one most packaging producers will recognise. It is where post-consumer recycled content and secondary raw material turn up.
What changes when a supplier hands you a PCDS
Most companies already ask their suppliers circularity questions. What changes is what comes back.
Without a shared format, a procurement team sends out its own questionnaire and every supplier answers in their own words, in their own layout, in whichever file type they happen to use.
Comparing two suppliers means reading two documents and interpreting both. Rolling fifty of them into one number means doing that fifty times by hand.
With a PCDS, the questions were written once, the answers are True or False, and the numbering is fixed. The same fact sits in the same slot on every sheet, so the comparison stops being a reading exercise and becomes something a system can do.
One honest limit is written into the standard itself. Different suppliers can use different methods to work out their own circularity facts, so two sheets are not automatically comparable in every respect.
That is why a PCDS also carries the supplier's specifications and supplementary information, and why the standard tells buyers to actually read them.
Who fills in a PCDS and who reads it
ISO 59040 is built around a pair of roles rather than an industry, which is why it applies to organisations of any type or size.
- The supplier fills the sheet in. In the standard's terms that is whoever agrees to supply the product, so a producer, a manufacturer, a distributor, a retailer or a vendor.
- The acquirer reads it. That is whoever is buying or procuring the product, anywhere from a purchasing department to the end user.
Inside a real company the work rarely sits with one person. Product and engineering teams know what the thing is made of and how it comes apart.
Procurement decides which suppliers are asked for a sheet in the first place. Sustainability and compliance teams are the ones who need the answers months later.
The standard also recognises that a small supplier needs more help than a large one, and points to training and a transition period as reasonable ways to handle that rather than expecting everyone to be ready on day one.
Where ISO 59040 fits for packaging producers
Nothing in EU packaging law requires a PCDS. The Packaging and Packaging Waste Regulation, or PPWR, does not mention ISO 59040, and using the format is entirely voluntary.
What makes it worth knowing about anyway is that the sheet asks suppliers for very nearly the facts a packaging producer has to hold on their own account.
- Substances. The regulation restricts substances of concern in packaging. A PCDS has a module for hazardous substances and substances of concern.
- Recycled content. From 2030, plastic packaging has to meet minimum post-consumer recycled percentages. A PCDS has modules for product composition and recycled materials.
- Recyclability. Packaging has to reach recyclability grades on a phased timeline. A PCDS has a recycling module.
- The paperwork. The EU Declaration of Conformity and the technical file sitting behind it are built on facts about the packaging that mostly originate with suppliers.
None of that is automatic, and it is worth being blunt about the gap. A supplier marking a statement True is making their claim, not discharging your obligation. What a standard format changes is the asking, not the answering.
For a producer already chasing the same suppliers for the same figures every year, that is the practical appeal. The same answers feed the Extended Producer Responsibility (EPR) reports that come round again every year.
Keeping them somewhere they can be queried later, rather than scattered across an inbox, is the kind of record an EPR reporting platform exists to hold.
How ISO 59040 relates to the other ISO 59000 standards
ISO 59040 is one of a set of circular economy standards that were written to work together, and it leans on two of them directly.
| Standard | What it does |
|---|---|
| ISO 59004, 2024 | Vocabulary, principles and guidance. ISO 59040 takes its definitions from here |
| ISO 59010, 2024 | Guidance on moving business models and value networks onto a circular footing |
| ISO 59014, 2024 | Sustainability and traceability of recovered secondary materials |
| ISO 59020, 2024 | Measuring and assessing how circular something actually is |
| ISO 59040, 2025 | Sharing one product's circularity facts with the company buying it |
Two other documents get mixed up with a PCDS often enough to be worth separating out.
A PCDS is not an environmental product declaration. An EPD under ISO 14025 reports quantified life cycle impacts, calculated against published product category rules and verified by an independent party.
A PCDS reports circularity facts as True or False and leaves the checking to whatever the buyer and supplier agreed between them.
A PCDS is not a digital product passport. The digital product passport is a separate EU instrument arriving under the ecodesign rules.
ISO 59040 goes no further than saying the data a PCDS collects can be used for digitalised product documentation. That makes it useful input, not the same thing.
ISO 59040 questions answered
Short, plain answers to the questions that come up most often about ISO 59040.
What is ISO 59040?
ISO 59040 is the international standard, published in 2025, that defines the product circularity data sheet. It sets out one fixed format a supplier uses to report a product's circularity facts to the company buying it, without giving away confidential business information.
What is a product circularity data sheet?
A PCDS is a product declaration presenting standardised information about how circular a product is. A supplier completes it for one specific product using a template, and the answers to its statements are given as True or False so a buyer can compare products from different suppliers.
Is ISO 59040 a certification?
No. There is no certificate and no accredited certification scheme attached to ISO 59040. A supplier conforms to the standard by answering every mandatory statement on the template, and the buyer and supplier agree separately how that sheet gets checked.
Is a PCDS mandatory?
No. ISO 59040 is a voluntary standard and no EU packaging law currently requires a PCDS. Companies use it because a shared format makes supplier data comparable, or because a customer asks for it as part of a purchasing agreement.
How does a PCDS protect confidential information?
Because the answers are limited to True or False, a supplier can confirm that a product meets a given circularity condition without publishing the underlying figure, recipe or source. The buyer gets the fact they need and the commercial detail behind it stays with the supplier.
Who checks that a PCDS is accurate?
ISO 59040 lets the conformity assessment be carried out by the supplier itself, by the buyer, or by an authorised third party. The two parties agree the method in advance, which can be a process audit, a verification of the individual statements, or both combined.
What is the difference between a PCDS and an environmental product declaration?
An environmental product declaration under ISO 14025 reports quantified life cycle impacts, worked out against published product category rules and independently verified.
A PCDS reports circularity characteristics as True or False statements exchanged between a supplier and a buyer, and it is not verified by default.
What edition of ISO 59040 is current?
The 2025 edition is the only one. ISO 59040:2025 is the first edition of the standard, prepared by ISO/TC 323, the ISO technical committee for the circular economy.
