EPD (Environmental Product Declaration): Why Construction Materials Need It

EN 15804 Modules and Life Cycle Stages

The A-D Module Structure

EN 15804 divides a product's life cycle into four main stages (A-D), subdivided into 17 modules. This standardized structure ensures that EPDs from different manufacturers use consistent system boundaries and can be compared or aggregated in whole-building LCA.

A1-A3: Product Stage (Cradle-to-Gate)

The product stage covers raw material extraction, transport to manufacturing site, and manufacturing itself:

• A1 (Raw material supply): Extraction and processing of raw materials (e.g., mining iron ore, quarrying limestone, harvesting timber). Includes upstream impacts (e.g., fuel for mining equipment, electricity for ore processing).
• A2 (Transport to manufacturer): Transport of raw materials from extraction site to manufacturing facility (tkm = tonne-kilometers; e.g., 100 tonnes transported 500 km = 50,000 tkm).
• A3 (Manufacturing): Energy and materials consumed during product manufacturing (e.g., electricity for steel rolling, natural gas for cement kiln, water for concrete mixing). Includes process emissions (e.g., CO₂ from calcination), waste generation, and packaging.

A1-A3 modules are mandatory for all EPDs. Three EPD types under EN 15804: Cradle-to-gate, Cradle-to-grave, and Cradle-to-gate with options. (Source) Cradle-to-gate EPDs report only A1-A3.

A4-A5: Construction Process Stage

• A4 (Transport to construction site): Transport of finished product from factory gate to construction site. Typically reported as "options" in cradle-to-gate-with-options EPDs, since transport distance varies by project location.
• A5 (Construction/installation): Energy, water, and waste associated with installing the product on-site (e.g., diesel for cranes, water for curing concrete, waste from cutting insulation to fit).

B1-B7: Use Stage

The use stage covers environmental impacts during the building's operational life (typically 50-100 years for structural components):

• B1 (Use): Emissions from the product itself during use (e.g., formaldehyde off-gassing from insulation, carbonation of concrete absorbing CO₂).
• B2 (Maintenance): Cleaning, inspections, minor repairs (e.g., repainting steel, cleaning glass facades).
• B3 (Repair): Major repairs or component replacement (e.g., replacing failed sealant, repairing concrete spalling).
• B4 (Replacement): Full replacement of product during building life (e.g., replacing insulation after 30 years, replacing windows after 40 years).
• B5 (Refurbishment): Building-level renovations affecting the product (e.g., facade upgrade, structural strengthening).
• B6 (Operational energy use): Energy consumed by the product during use (typically N/A for passive materials like concrete or insulation; relevant for active systems like HVAC or lighting).
• B7 (Operational water use): Water consumed by the product during use (typically N/A for most construction materials).

B-modules are often reported as "options" or excluded for products with minimal use-stage impacts (e.g., structural steel has no B1-B5 impacts if properly protected from corrosion).

C1-C4: End-of-Life Stage

• C1 (Deconstruction/demolition): Energy and emissions from dismantling or demolishing the product (e.g., diesel for excavators, dust/noise emissions).
• C2 (Transport to waste processing): Transport of waste material from demolition site to landfill, recycling facility, or incinerator.
• C3 (Waste processing): Sorting, shredding, cleaning, or other processing before final disposal or recycling (e.g., crushing concrete for aggregate, melting steel scrap).
• C4 (Disposal): Final disposal (landfill, incineration) or recovery (recycling, energy recovery). Emissions from landfill decomposition or incineration are included here.

D: Benefits and Loads Beyond the System Boundary

Module D captures environmental benefits (or loads) from reuse, recycling, or energy recovery that occur outside the product's life cycle boundary. For example:

• Steel recycling: If 1 tonne of steel is recycled at end-of-life, the recycled steel displaces primary steel production, avoiding ~1.8 tonnes CO₂e. This avoided impact is credited in Module D.
• Timber energy recovery: If timber is incinerated for energy at end-of-life, the recovered energy displaces fossil fuel combustion, creating a credit in Module D.
• Concrete aggregate reuse: If crushed concrete is used as road base, it displaces quarried aggregate, creating a credit in Module D.

Module D is controversial because it credits future benefits that may not materialize (e.g., if recycling rates decline, or if displaced materials have lower environmental impact than assumed). EN 15804+A2 requires Module D to be reported separately (not added to A-C totals) to maintain transparency.

Cradle-to-Gate vs. Cradle-to-Gate with Options vs. Cradle-to-Grave

Why Construction Materials Need EPDs (The Business and Regulatory Case)

Building Certification Schemes Credit EPDs

BREEAM, LEED, and WELL award credits for products with verified environmental product declarations, recognising value of transparent life cycle data. (Source) Specific examples:

LEED v4 and v5 (US Green Building Council)

• Material Ingredients (1 point): Use products with publicly available EPDs (at least 20 permanently installed products from at least 5 manufacturers).
• Environmental Product Declarations (1-2 points): Use products with industry-wide (generic) EPDs or product-specific EPDs for significant building materials (structural frame, envelope, flooring, ceilings). Projects can earn 1 point for industry-wide EPDs or 2 points for product-specific EPDs covering ≥50% of project cost.
• Whole Building Life Cycle Assessment (3-6 points): Conduct whole-building LCA demonstrating reduced environmental impact vs. baseline. EPDs are the primary data source for product-level impacts in the LCA model.

BREEAM International (BRE Global)

• Life Cycle Impacts (Mat 01, up to 6 credits): Conduct whole-life carbon assessment using EPD data. Projects must demonstrate embodied carbon reductions vs. baseline, with EPDs providing verified product data.
• Responsible Sourcing (Mat 03, up to 4 credits): Use materials with third-party certification (including EPDs) for at least 80% of project value.

WELL Building Standard (International WELL Building Institute)

• Materials Transparency (Feature X06, optimization): Use products with EPDs or Health Product Declarations (HPDs) for building materials affecting indoor air quality.

Level(s) (European Commission)

Level(s) is the EU's voluntary framework for sustainable buildings, developed by the Joint Research Centre. It requires reporting on embodied carbon (Indicator 1.2) using EPD data for major building materials. While currently voluntary, Level(s) is being integrated into national building codes (Netherlands, France) and may become mandatory for public buildings by 2027.

PAS 2080 (UK Infrastructure Carbon Management)

PAS 2080 is the UK standard for whole-life carbon management in infrastructure. EPDs provide critical input for Whole Life Cycle Assessment (WLCA), enabling developers to meet sustainable building targets under RIBA and PAS 2080 guidance. (Source) Major UK infrastructure clients (Highways England, Network Rail, Thames Water) require PAS 2080 compliance, making EPDs essential for suppliers.

RIBA 2030 Climate Challenge (Royal Institute of British Architects)

RIBA 2030 sets embodied carbon targets for buildings: ≤625 kg CO₂e/m² for new construction (2025 target), declining to ≤350 kg CO₂e/m² (2030 target). Architects use EPD data to model embodied carbon and specify low-carbon materials to meet these targets.

Procurement Policies Increasingly Mandate Verified Embodied Carbon Data

EPDs often comply with recognised standards and certifications such as PAS 2080, LEED, BREEAM, and Level(s). (Source) Public procurement agencies are embedding embodied carbon requirements into tender specifications:

• Netherlands: Rijksgebouwendienst (central government property agency) requires EPDs for concrete, steel, and timber in all public buildings >€5M construction value (2022 policy).
• France: RE2020 regulation (effective 2022) mandates whole-life carbon assessments for all new buildings, with EPDs as the primary data source for product-level impacts. Non-compliance results in building permit denial.
• Germany: Bewertungssystem Nachhaltiges Bauen (BNB) for federal buildings requires embodied carbon reporting using EPD data.
• UK: Government Construction Strategy (2021-2025) requires whole-life carbon assessments for all central government projects >£5M, with EPDs mandated for major materials (concrete, steel, insulation, cladding).
• California, USA: Buy Clean California Act (AB 262, 2017) requires embodied carbon disclosure (via EPDs) for steel, glass, and insulation used in state-funded projects. Non-compliant products are excluded from procurement.

Competitive Disadvantage: Materials Without EPDs Excluded from Tenders

Manufacturers with verified EPDs are more likely to be preferred in tenders and procurement processes. (Source) The market dynamic is shifting:

• 2015-2020: EPDs were a "nice to have" differentiator. Projects pursuing high certification levels (LEED Platinum, BREEAM Outstanding) requested EPDs, but manufacturers without EPDs could still compete on price or technical performance.
• 2020-2025: EPDs became a "should have" for major projects. Developers increasingly write tender specifications requiring EPDs for embodied carbon reporting, but some flexibility remained (e.g., accepting industry-average data if product-specific EPDs unavailable).
• 2025-2030: EPDs are becoming "must have" for compliance. Mandatory embodied carbon disclosure policies (France RE2020, UK government procurement, California Buy Clean) exclude products without EPDs from eligibility. Manufacturers without EPDs are locked out of high-value public procurement markets.

The Economics of EPD Development

Cost Drivers

1. LCA Consultant Fees

Unless the manufacturer has in-house LCA expertise and software licenses (SimaPro/GaBi: €3,000-8,000/year), external LCA consultants are required. Typical consultant fees:

• Simple product (single-material, low processing complexity): €8,000-15,000 (e.g., timber boards, basic insulation, glass panels)
• Moderate complexity (multi-material, moderate processing): €15,000-30,000 (e.g., composite insulation, coated steel, engineered timber)
• High complexity (multi-stage processing, byproducts, allocation challenges): €30,000-60,000 (e.g., cement with multiple fuel sources, steel with blast furnace/EAF allocation, recycled-content composites)

Fees cover data collection support, LCA modeling, impact assessment, sensitivity analysis, and drafting the EPD document and internal LCA report.

2. Third-Party Verification

Independent verifiers charge €3,000-10,000 depending on product complexity and number of review rounds required. Complex products (e.g., concrete with multiple mix designs, steel with multiple production routes) require more verification effort.

3. Program Operator Fees

EPD program operators charge registration and annual maintenance fees:

• Registration fee: €500-2,000 (one-time, upon first EPD publication)
• Annual maintenance fee: €300-1,000 (to maintain EPD in registry during 5-year validity period)
• Verification coordination fee: Some POs charge €500-1,500 for coordinating verifier assignment and verification process

4. Data Collection Burden (Internal Labor)

Manufacturers must allocate internal staff time to:

• Compile production data (energy bills, material invoices, waste records): 20-60 hours
• Engage with suppliers to obtain upstream data or EPDs (e.g., steel supplier's EPD for rebar used in precast concrete): 10-40 hours
• Review and approve LCA consultant's draft reports: 10-30 hours
• Respond to verifier queries and provide additional documentation: 10-20 hours

Total internal labor: 50-150 hours (roughly 1-4 weeks of full-time effort spread over 4-12 months). For SMEs without dedicated sustainability staff, this represents significant opportunity cost.

Time: Typical 4-12 Months Depending on Product Complexity and Data Availability

Fast-Track Scenario (4-6 months)

• Simple product with well-documented production data
• Established PCR and PO with short verification queues
• Manufacturer has prior LCA experience or strong internal data systems
• Example: Timber product manufacturer with FSC certification and existing environmental management system (ISO 14001)

Standard Scenario (6-9 months)

• Moderate complexity product
• Some data gaps requiring supplier engagement or secondary data substitution
• 1-2 verification review rounds
• Example: Insulation manufacturer with multiple product lines seeking EPDs for 3 core products

Extended Scenario (9-12+ months)

• High complexity product (e.g., steel, cement, composites)
• Significant data collection challenges (e.g., multiple production sites, complex supply chains)
• Multiple verification rounds due to methodology disputes or data quality issues
• New PCR development required (adds 6-12 months)
• Example: Concrete producer developing EPDs for 15 mix designs across 5 plants

Renewal: EPDs Valid 5 Years; Must Be Updated with New Data

After 5 years, the EPD expires. To maintain market access, manufacturers must:

1. Update production data (last 12 months of production)
2. Re-run LCA with updated data (impact results may change if production efficiency improved or raw material sources changed)
3. Re-verify EPD (typically faster than initial verification: €2,000-5,000)
4. Re-register EPD (PO registration fee: €500-1,000)

Renewal cost: typically 30-50% of initial EPD development cost (€5,000-20,000 depending on complexity). Renewal timeline: 2-4 months if production process and data systems are stable.

EPD Development Checklist

EPDs and Circular Construction (Materials Passports, Reuse, BIM Integration)

EPDs as Foundation for Materials Passports

EPDs provide third-party verified data on product's environmental impact across life-cycle, with independent verification ensuring reliability. (Source) Materials passports are digital records tracking a building material's composition, performance characteristics, and recovery potential. They enable circular construction by documenting:

• Material composition: Exact chemical composition and material mix (critical for assessing recycling feasibility)
• Performance characteristics: Structural properties, thermal performance, durability (determines potential for reuse vs. downcycling)
• Disassembly instructions: How to remove material from building without damage (e.g., reversible connections, modular systems)
• Environmental profile: Embodied carbon, resource use, toxicity (from EPD data)—informs reuse vs. recycling vs. disposal decisions

EPDs support compliance with embodied carbon reduction targets while materials passports enhance circularity by tracking material provenance and reuse potential. (Source) For example:

• A structural steel beam with an EPD showing 1.2 tonnes CO₂e/tonne (including recycled content) and a materials passport documenting bolt connections (reversible) can be prioritized for reuse in future buildings, avoiding 1.2 tonnes CO₂e per tonne reused.
• Insulation with an EPD showing high embodied carbon (e.g., 5 kg CO₂e/kg for petrochemical foam) and a materials passport indicating contamination risk (e.g., fire retardants) may be targeted for replacement with bio-based alternatives in retrofit projects.

Integration into BIM Workflows for Whole-Life Carbon Assessments

Building Information Modeling (BIM) software (Revit, ArchiCAD, Tekla) is increasingly used to conduct whole-life carbon assessments during design. EPDs are integrated into BIM workflows through:

1. EPD Databases Linked to BIM Objects

Tools like One Click LCA, Tally (Revit plugin), and eLCA (Germany) link BIM objects (walls, beams, slabs) to EPD databases. When an architect specifies a material in the BIM model (e.g., "200mm concrete slab, C30/37 strength class"), the tool automatically retrieves the relevant EPD and calculates embodied carbon for that building element.

2. Real-Time Carbon Feedback During Design

As architects modify the design (e.g., changing from concrete to cross-laminated timber structure), the BIM-integrated LCA tool updates whole-building embodied carbon in real-time. This enables "carbon-optimized design": iterating through design options to minimize embodied carbon while meeting performance and cost targets.

3. Digital EPDs and Machine-Readable Formats

ECO EPDs available in digital format via ECO Portal datahub, enabling direct machine-readable access for LCA tools and other applications. (Source) ECO EPDs are EPDs that comply with EN 15804 issued by established EPD programmes that are members of ECO Platform; recognised throughout Europe. (Source)

Traditional EPDs are PDF documents requiring manual data entry into LCA tools (error-prone and time-consuming). Digital EPDs (ECO Platform format, JSON/XML schemas) are machine-readable, allowing automatic import into BIM/LCA software. This reduces data entry errors and accelerates whole-building LCA workflows.

4. Scenario Analysis and Material Substitution

BIM-integrated LCA tools allow designers to test scenarios:

• "What if we switch from 150mm concrete slab to 120mm concrete + 30mm screed?" → embodied carbon changes from 180 kg CO₂e/m² to 165 kg CO₂e/m²
• "What if we specify low-carbon cement (CEM III with 70% slag) instead of CEM I?" → embodied carbon changes from 400 kg CO₂e/m³ to 280 kg CO₂e/m³
• "What if we use steel with 90% recycled content instead of 30%?" → embodied carbon changes from 2.1 tonnes CO₂e/tonne to 1.0 tonnes CO₂e/tonne

These scenarios are only possible with granular EPD data for specific products and material variants.

Case Studies (2 Worked Examples)

Example A: Concrete Manufacturer Obtaining EN 15804+A2 EPD to Access European Projects

Example B: Insulation Manufacturer Using EPD to Win LEED/BREEAM Credits for Clients

Devil's Advocate (7 Objections to EPD Requirements)

Objection 1: Cost Burden for SMEs

The objection: EPD development costs (€20,000-80,000 over 5 years) are prohibitive for small and medium-sized manufacturers with limited revenue and no dedicated sustainability staff. Large multinational corporations can absorb these costs easily, but SMEs face a disproportionate burden, potentially forcing market consolidation and eliminating regional suppliers.

When valid: True for very small manufacturers (<€5M annual revenue, single-product lines) serving niche local markets where EPD demand is limited. For these businesses, EPD ROI may be negative if procurement policies don't mandate EPDs in their target markets.

Mitigation: Industry associations are developing shared EPDs (one EPD covering multiple manufacturers producing to the same specification, sharing verification costs). Some EPD program operators offer "small producer" discounts (reduced fees for manufacturers <€10M revenue). Government grants for sustainability certification (available in Germany, Netherlands, UK) can offset 30-50% of EPD costs for SMEs. Strategic alternative: focus on regional markets with lower EPD adoption and compete on service/delivery speed rather than sustainability credentials.

Objection 2: Data Confidentiality Concerns

The objection: EPDs require disclosure of production data (energy consumption, raw material quantities, process emissions) that manufacturers consider commercially sensitive. Competitors could reverse-engineer production costs or identify efficiency weaknesses from EPD data. This concern is especially acute for proprietary products or processes where competitive advantage depends on trade secrets.

When valid: Partially valid. EPDs do require disclosure of aggregated production data (e.g., "400 kWh electricity per tonne of product"), but detailed process parameters (temperatures, pressures, catalyst formulations) are not disclosed. However, experienced competitors can estimate production costs from EPD energy/material inputs.

Mitigation: EPD standards allow data aggregation and normalization that protects confidentiality. For example, a manufacturer operating 3 plants can publish a single "average" EPD rather than plant-specific EPDs, masking individual plant performance. Additionally, since EN 15804 EPD is a Type III EPD (ISO 14025), stringent requirements for publication apply; requires verification process and is subject to administration of a program operator (Source), ensuring that all competitors face the same disclosure requirements—leveling the playing field. If confidentiality risk is unacceptable, manufacturer can choose not to pursue EPD, but this means forfeiting markets where EPDs are mandatory.

Objection 3: PCR Fragmentation Limits Comparability

The objection: Different EPD program operators develop different Product Category Rules (PCRs) for the same product categories. For example, "structural steel" has separate PCRs from IES, IBU, and UL, with slightly different system boundaries, allocation methods, and functional units. This fragmentation undermines EPD comparability—the core value proposition of standardized environmental declarations.

When valid: Valid concern. PCR fragmentation is a real problem, especially in global markets where manufacturers must navigate multiple PCRs for the same product. A steel manufacturer exporting to both Europe and North America may need separate EPDs (EN 15804 for Europe, ISO 21930 for North America), duplicating costs.

Mitigation: Because ISO 21930 is strongly similar to EN 15804, there will likely be better cross-recognition between North American and European LCAs. (Source) PCR convergence is accelerating as ISO 21930 (2017 update) aligned more closely with EN 15804+A2 (2019). EPD program operators are also developing mutual recognition agreements (e.g., IES and UL recognize each other's EPDs for specific product categories). Long-term solution: global PCR harmonization under ISO working groups (ongoing; expected completion 2026-2028 for major construction product categories).

Objection 4: Greenwashing Risk—EPDs Without Improvement

The objection: EPDs are disclosure tools, not performance standards. A manufacturer can publish an EPD showing very high embodied carbon (e.g., cement at 900 kg CO₂/tonne) and still claim "transparency" and "verified environmental data" without actually improving environmental performance. This creates "greenwashing by disclosure"—appearing sustainable by publishing data while continuing high-impact production.

When valid: Partially valid. EPDs alone do not drive improvement—they are information tools. However, they enable market pressure: specifiers can compare EPDs and choose lower-carbon alternatives, creating competitive pressure for high-carbon producers to improve. Additionally, procurement policies increasingly set embodied carbon thresholds (e.g., "concrete with GWP <300 kg CO₂e/m³"), making EPDs a prerequisite but not sufficient—products must also meet performance benchmarks.

Mitigation: Combine EPDs with performance standards. France's RE2020 and UK RIBA 2030 set maximum embodied carbon limits—EPDs provide the data, but products exceeding thresholds are excluded regardless of EPD transparency. Industry leadership programs (e.g., Concrete Sustainability Council, ResponsibleSteel) set environmental performance criteria beyond EPD disclosure. Specifiers should use EPDs to compare products, not as a pass/fail certification.

Objection 5: EPD "Box-Ticking" Without Real Environmental Benefit

The objection: EPDs have become a compliance checkbox for LEED/BREEAM credits rather than a tool for genuine environmental improvement. Architects specify products with EPDs to earn certification points, but don't actually use EPD data to optimize building design or select lower-impact materials. This creates a market for "EPD as a service" (consultants churning out EPDs to meet compliance) without driving meaningful carbon reductions.

When valid: Valid in some cases. Early LEED/BREEAM projects (2015-2020) often pursued EPD credits by specifying any products with EPDs, regardless of environmental performance. This created demand for EPDs but limited environmental benefit.

Mitigation: Evolving certification schemes now require EPDs to be used in whole-building LCA optimization, not just as standalone credits. LEED v5 (expected 2025-2026) will shift from "credit for having EPDs" to "credit for achieving embodied carbon reduction targets using EPD data." BREEAM 2018+ requires EPDs to inform material selection decisions, not just documentation. Additionally, EPDs provide critical input for Whole Life Cycle Assessment (WLCA), enabling developers to meet sustainable building targets under RIBA and PAS 2080 guidance (Source), driving real optimization. As BIM-integrated LCA tools mature, EPD data will increasingly drive design decisions in real-time, reducing "box-ticking" behavior.

Objection 6: Short Validity Period (5 Years) Creates Renewal Overhead

The objection: EPDs expire after 5 years, requiring renewal with updated production data and re-verification. For manufacturers with stable production processes, this creates recurring costs (€5,000-20,000 every 5 years) without adding value—environmental performance may not change significantly, but EPD must be updated anyway. This is especially burdensome for products with long development cycles (e.g., proprietary insulation formulations) where production parameters remain constant for decades.

When valid: Valid for mature products with stable production. However, 5-year validity ensures EPD data reflects current production practices, accounting for changes in electricity grid mix (which affects upstream impacts), raw material sourcing (e.g., switch to higher recycled content), or process improvements (e.g., energy efficiency upgrades). Without periodic updates, EPDs would become outdated and misleading.

Mitigation: Some EPD program operators are piloting "evergreen EPDs" with annual data updates instead of full 5-year renewal, reducing verification costs. Manufacturers can streamline renewals by maintaining continuous LCA data systems (integrating production data logging with LCA software), reducing data collection effort. Industry associations are lobbying for extended validity periods (7-10 years) for mature product categories with low variability, but this requires standards body approval (ISO/CEN working groups).

Objection 7: Cross-Border Recognition Issues

The objection: EPDs developed under one program operator (e.g., IBU in Germany) may not be automatically recognized by certification schemes or procurement agencies in other countries. A manufacturer with an EN 15804+A2 EPD from IBU may be asked to obtain a separate EPD from a local program operator (e.g., BRE in UK, INIES in France) to qualify for local projects, duplicating costs and effort.

When valid: Partially valid. While EN 15804 is a European standard (applicable across EU), some national procurement agencies prefer EPDs from local program operators for language/cultural reasons. Non-EU markets (USA, Canada, Asia-Pacific) may not recognize EN 15804 EPDs without additional documentation.

Mitigation: ECO EPDs are EPDs that comply with EN 15804 issued by established EPD programmes that are members of ECO Platform; recognised throughout Europe. (Source) ECO EPDs available in digital format via ECO Portal datahub, enabling direct machine-readable access for LCA tools and other applications (Source), improving cross-border usability. For global markets, manufacturers should prioritize EN 15804+A2 or ISO 21930 EPDs (increasingly recognized worldwide) and register with ECO Platform for European recognition. Mutual recognition agreements between program operators (IES, IBU, BRE, UL) are expanding, reducing need for duplicate EPDs.

Outlook to 2027–2030

Regulatory Trends: EPDs Moving from Voluntary to Mandatory in Public Procurement

European Union

EPDs often comply with recognised standards and certifications such as PAS 2080, LEED, BREEAM, and Level(s). (Source) The EU's Level(s) framework is being integrated into national building codes:

• France: RE2020 regulation (effective 2022) mandates embodied carbon disclosure via EPDs for all new buildings. By 2028, maximum embodied carbon thresholds will be introduced (declining from baseline to 2030 targets), making low-carbon EPDs a competitive requirement, not just a disclosure obligation.
• Netherlands: Environmental Performance of Buildings (MPG) regulation requires whole-life carbon assessments for all buildings >100 m². EPDs are the mandated data source for product-level impacts. Non-compliance results in building permit denial.
• Germany: Quality Seal for Sustainable Buildings (QNG) for residential buildings (launched 2023) requires embodied carbon reporting via EPDs. Expected to expand to commercial buildings by 2026.
• Denmark: Voluntary embodied carbon limits (2023) transitioning to mandatory limits for public buildings (2025) and all new buildings (2027). EPDs required for compliance documentation.

United Kingdom

Government Construction Strategy (2021-2025) requires whole-life carbon assessments for all central government projects >£5M, with EPDs mandated for major materials. The UK Green Building Council (UKGBC) is advocating for embodied carbon limits in Building Regulations Part Z (expected 2026-2028 consultation), which would make EPDs legally required for compliance.

North America

• California: Buy Clean California Act (AB 262, 2017) requires embodied carbon disclosure (via EPDs) for steel, glass, and insulation in state-funded projects. Expansion to concrete, timber, and drywall expected by 2026. Maximum embodied carbon limits (Buy Clean thresholds) likely by 2028.
• Washington State: Buy Clean Buy Fair Washington Act (2021) mandates EPDs for structural steel and concrete in public projects >$12M. Expanding to other materials by 2025.
• Federal (USA): Federal Buy Clean Initiative (announced 2022) proposes EPD requirements for federally funded infrastructure (highways, bridges, federal buildings). Implementation timeline: 2025-2027 (pending rulemaking).

Digital EPDs and Machine-Readable Formats (ECO Portal)

ECO EPDs available in digital format via ECO Portal datahub, enabling direct machine-readable access for LCA tools and other applications. (Source) Key developments:

1. Machine-Readable EPD Standards

ECO Platform (European coalition of EPD program operators) has developed a digital EPD format (XML/JSON schema) enabling automatic data exchange between EPD databases and LCA/BIM software. By 2027, most EPDs published in Europe will be available in digital format, eliminating manual data entry and reducing errors in whole-building LCA.

2. API Integration with BIM Tools

ECO Portal provides APIs (application programming interfaces) allowing BIM software (Revit, ArchiCAD) to query EPD databases in real-time. Architects specifying a product in BIM automatically retrieve the latest EPD data, ensuring LCA models use current verified data.

3. Blockchain for EPD Verification

Pilot projects (Germany, Netherlands) are testing blockchain-based EPD registries to create tamper-proof records of EPD issuance, transfers, and expiration. This could reduce verification fraud risk and streamline cross-border EPD recognition.

4. AI-Assisted EPD Development

LCA software vendors are developing AI tools to automate parts of EPD development: extracting production data from ERP systems, suggesting allocation methodologies based on PCR requirements, and flagging data quality issues. This could reduce EPD development time from 6-12 months to 3-6 months and cut consultant fees by 20-30% by 2028-2030.

Integration with Carbon Pricing and Building Performance Regulations

Carbon Pricing for Embodied Carbon

Some jurisdictions are exploring embodied carbon pricing (similar to operational carbon pricing via EU ETS or carbon taxes):

• Netherlands: Proposal to extend EU ETS to embodied carbon in buildings (2027 target). Buildings exceeding embodied carbon thresholds would incur carbon charges (€50-100/tonne CO₂e), incentivizing low-carbon material selection. EPDs would provide the data for carbon charge calculations.
• UK: HM Treasury consulting on "Embodied Carbon Tax" for construction materials (2025 Green Budget discussions). If implemented (2028+), materials with high embodied carbon (per EPD data) would face tax surcharges, creating direct financial incentive for low-carbon EPDs.

Building Performance Standards Integrating Embodied Carbon

Operational carbon regulations (e.g., Nearly Zero Energy Buildings in EU, ASHRAE 90.1 in USA) are expanding to include embodied carbon:

• EU: Energy Performance of Buildings Directive (EPBD) recast (expected 2024-2025) will add embodied carbon reporting to Energy Performance Certificates (EPCs). Buildings with high embodied carbon may receive lower EPC ratings, affecting resale value and rental marketability. EPDs will be the data source for embodied carbon in EPCs.
• California: Title 24 Building Standards (2025 update) is considering embodied carbon limits for new buildings. EPDs would be required for compliance documentation, similar to operational energy modeling requirements.

Market Forecast: EPD Penetration by 2030

• Europe: 80-90% of construction product value in public procurement will require EPDs by 2030 (up from ~30% in 2025). Private sector adoption will reach 50-60% (driven by LEED/BREEAM/green financing requirements).
• North America: 40-50% of public procurement and 30-40% of private sector projects will require EPDs by 2030 (up from ~15% in 2025). Growth driven by Buy Clean laws and LEED v5 adoption.
• Asia-Pacific: 20-30% penetration by 2030 (from ~5% in 2025), led by green building uptake in Singapore, Australia, Japan, and South Korea. China's Green Building Evaluation Standard may integrate EPD requirements by 2028.

What Manufacturers Should Do Now

1. Obtain EPDs for core products immediately if targeting European or North American markets where mandatory disclosure is imminent (2025-2027). Delay risks market exclusion.
2. Invest in low-carbon production improvements before obtaining EPDs. EPDs are disclosure tools—differentiate by having low embodied carbon to disclose, not just transparency.
3. Prepare for digital EPD formats. Ensure your EPDs are registered with ECO Platform (Europe) or compatible digital formats for North America. Machine-readable EPDs will become table stakes for BIM workflows by 2027-2028.
4. Engage in PCR development. If your product category lacks a PCR or existing PCRs are outdated, participate in industry working groups to shape PCR rules favorably (system boundaries, allocation methods, functional units).
5. Monitor regulatory developments. Subscribe to updates from national building authorities (France: DHUP, Netherlands: Rijksoverheid, UK: MHCLG, California: DGS) to anticipate mandatory EPD requirements before they take effect.