Environmental product declarations: why does the industry need more EPDs?

Legislation around the world is increasingly mandating the reporting of embodied carbon and use of more sustainable products in buildings. At a recent webinar, held in collaboration with the Alliance for Sustainable Building Products, a panel of experts discussed the use, drivers and barriers of environmental product declaration (EPD) adoption in the built environment. 

Environmental product declarations (EPDs) are being increasingly employed by designers, the wider supply chain and regulatory authorities to understand the environmental impacts that buildings and infrastructure have. While technology, data and skills present barriers to adoption, industry and regulatory initiatives will see a more complete adoption of EPDs in the built environment.

EPDs are becoming a global phenomenon

At the start of 2024, there were nearly 25,000 EPDs published to the European standard EN 15804. But there are at least another 30,000 project-specific EPDs that have been verified for European products, and around 70,000 verified EPDs in North America, explains Dr Jane Anderson, ConstructionLCA and co-author of RICS’ Whole life carbon assessment professional standard. EPDs are also being produced in Australasia, China, Mexico and Latin America, as well as in the Middle East and India.

There are numerous EPD programmes in Europe and around the world that use the EN 15804 standard. The EPDs will all have the same common content and follow the same rules, for example, the way that the building life cycle is broken down. This means the EPD data can be plugged into a building or infrastructure life cycle assessment, explains Jane.

EPDs examine a spectrum of environmental impacts, not just carbon

‘An EPD isn't a statement that something is sustainable or not, but rather a report that shows in a verifiable objective way that a product has various impacts across a series of categories’, states Mark Lynn, managing director of Eden Renewable Innovations Ltd.

‘Looking at the information they contain, it’s not just carbon, although carbon tends to be the indicator that we focus on most of all, with things like embodied carbon’, says Jane. There is a list of core indicators that are mandatory in every EPD, with impact categories covering drivers of climate change, ozone depletion, acidification, eutrophication, water use and ozone formation. It is mandatory for EPDS to cover all the impacts up until the product leaves the factory gates. EPDs include resource indicators and indicators about the amount of material available for reuse or recycling based on certain scenarios. More recently, EPDs must provide information on biogenic carbon.

What are the primary drivers of EPD adoption?

For countries and companies that want to reduce the embodied carbon in buildings, one approach is to use EPDs to find lower impact products or solutions. In Norway, there is a requirement to have at least ten products with EPDs on any large public projects. In Italy, there are requirements for public buildings to have a specific percentage of recycled content, so EPDs are a way of providing evidence of this. Germany and Belgium have requirements to assess the life cycle impacts of publicly funded buildings. Denmark, Finland and Sweden have regulations requiring the assessment of embodied carbon in buildings. Both BREAAM and LEED building assessment systems have credits for using products with EPDs.

‘In Europe, it will become mandatory to produce verified, digitised EPD data for products covered by either the Construction Products Regulations or the Eco Design Regulations, starting in the next couple of years with steel and concrete, and then ongoing until around 2040’, says Jane. So, if you want to market your product in the EU, you will have to produce an EPD. Products with the biggest impact are being prioritised, although sectors can also fast track, she continues. The Energy Performance of Buildings Directive means that by 2028, all large buildings in the EU member states will have to assess embodied carbon, and all new buildings by 2030. With these kinds of requirements coming into force, there will be a massive pull for EPD data, she concludes.

We are pushed by carbon regulation in Europe, by market requirements and of course by financial regulation as well, explains Frank Hovorka MRICS, board member and sustainability chair for RICS. ‘We are really pushed by corporate and social reporting directives. Every company must report its CO₂ emissions and greenhouse gas emissions to a standardised reporting system’.

The French EPD programme is among the largest in the world – how does it work?

Since January 2022, it has been mandatory to make life cycle assessments on buildings in France, continues Frank. This life cycle assessment is done based on a core calculation methodology developed by the French Scientific Centre for Buildings. At the building level, the French system requires a dynamic life cycle assessment, which considers biogenic carbon stocks at the end of life.

There is only one database – Inies – where construction product EPDs can be registered in France. To get onto the database, products must achieve certification with a French system of auditing. As the French system is different, an EPD produced in another country would not be able to go directly into the Inies database. However, all the information for the manufacture of the product in an EPD theoretically can be used, says Jane. The problem lies in the limited number of verifiers in France, which is a challenge shared by a lot of other countries as well.

Despite being among the largest EPDs programmes globally, the Inies database does not have sufficient manufacturer specific or sector EPD to provide for every single product and product group, explains Jane. This lack of EPDs, says Frank, means professionals must instead use a set of state-provided average values for certain families of products, or if not available, a proxy EPD. However, there is a high uplift if you must use these proxy EPDs, basically doubling the impact, so it is advantageous to have manufacturer specific and sector EPDs in the French database.

Using EPDs to inform product development

Mark Lynn is managing director of Eden Renewable Innovations Ltd, the company behind Thermafleece, among other construction products. Thermafleece is a natural fibre insulation made from British sheep's wool. ‘We chose to produce EPDs for our products because they provide a means to support our green claims and highlight our commitment to a sustainable built environment’, Mark explains.

EPDs also show a commitment to transparency and objectivity, and they also help to inform product development, he says. ‘It is very important for us and our culture as a business; we don’t see EPDs as a tick box exercise. You’ve got to embrace the EPD process and see how informative it can be internally, and how useful it can be externally’.

How can EPDs help to counter greenwashing?

Speaking about how accessible EPDs are for SMEs, Mark says, ‘I don't believe that EPDs are too expensive for small businesses. It's just a question of prioritising where you spend your money’.

Ultimately, putting together an EPD is a process mapping and data collection exercise for an SME, so finding the people with the right mindset for that kind of work was straightforward, he says. ‘Typically, we found that drafting the EPD would probably take three months and then it would require a month or so to get it verified. So, an SME is probably looking about six to nine months from start to finish’, he says. ‘And if you annualise the costs, it was less than £4,000 a year in total for two EPDs covering four products; so less than £1000 a year per product’.

Jane agrees, explaining that EPDs a are useful mechanism to counter the risk of greenwashing. ‘EPDs are independently verified by an experienced expert who must be approved by an EPD programme. If it's an ECO Platform EPD programme, it has been audited and the EPDs have been checked to make sure the verifiers are fully qualified, and a very detailed verification checklist ensures quality’, she says.

In France and Germany, it is already a requirement that you must have an EPD if you make an environmental claim about a construction product, and there is similar legislation coming through at the European level, continues Jane. In the UK, EPDs can be useful evidence of adherence to the Green Claims Code.

Data and technology solutions for integration are rapidly emerging

It is impossible to efficiently manage data for 400 to 600 building components in a spreadsheet, so a machine-to-machine readable system is needed, says Frank. He continues, ‘the challenge we face in Europe is to develop a normalised approach where each product has a unique identification tag and digital product passport, so that it can be integrated into a building’s digital twin’. To achieve this, data templates and data sharing approaches are being developed in the EU.

There are several other emerging data and technology solutions, adds Jane. The Built Environment Carbon Database is becoming more useful in finding EPDs that are relevant in the UK. The EC3 database can find products that have characteristics in particular locations. EPD Analyzer has a tool where you can make comparisons between EPD and visualise the results.

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