What is an EPD (Environmental Product Declaration)?

What an EPD Is

An Environmental Product Declaration (EPD) is a standardised document that communicates the quantified environmental performance of a product across multiple impact categories, based on a lifecycle assessment (LCA). Think of it as a nutritional label for a product’s environmental footprint: a single format that lets buyers, architects, specifiers, and policymakers compare the environmental impacts of competing products on a like-for-like basis.

EPDs are not marketing materials. They are prepared according to strict methodological rules set out in product category rules (PCRs), subjected to independent third-party critical review, and registered with an accredited programme operator. A verified EPD cannot be prepared by a company simply choosing the most favourable methodology; the rules governing what must be included, what system boundary applies, and how results must be reported are fixed in advance.

The primary environmental indicator in an EPD is Global Warming Potential (GWP), expressed in kgCO₂e per functional unit — the same unit used by the Climate Cost Index. EPDs typically also report additional impact categories: ozone depletion, acidification, eutrophication, photochemical ozone creation, resource depletion, and water use. For the purpose of carbon accounting, GWP is the most directly relevant figure.

Standards That Govern EPDs

Three international standards form the backbone of EPD methodology:

ISO 14025:2006 — Environmental labels and declarations: Type III environmental declarations. This is the overarching standard defining what a Type III declaration (the formal name for an EPD) is, how it must be structured, and what disclosure requirements apply. It establishes the framework but does not specify the LCA methodology in detail.

EN 15804:2012+A2:2019 — Sustainability of construction works. The dominant European standard for construction product EPDs. It specifies core product category rules (the “core PCR”) covering which lifecycle modules must be reported, how allocation must be handled, and what data quality requirements apply. EN 15804 uses a modular structure: Module A (cradle to practical completion), Module B (use stage), Module C (end of life), and Module D (beyond system boundary — reuse, recovery, recycling potential). Many non-construction EPDs follow EN 15804 methodology even outside the building sector because it is the most fully developed and internationally harmonised approach.

ISO 14067:2018 — Carbon footprint of products. A narrower standard focused specifically on the carbon footprint of a product, covering both GWP and biogenic carbon. ISO 14067 is frequently used for product carbon footprint certifications outside the construction sector — Apple’s and Samsung’s product environmental reports are certified per ISO 14067 and/or PAS 2050. When a manufacturer submits an ISO 14067-certified carbon footprint as a CCI provenance override, it is treated equivalently to a full EPD for the purposes of the GWP indicator.

PAS 2050:2011 (Publicly Available Specification, BSI) is a UK standard for assessing the lifecycle greenhouse gas emissions of goods and services. It predates ISO 14067 and has largely been superseded by it, but many verified product carbon footprints — particularly from the Carbon Trust — reference PAS 2050. CCI accepts PAS 2050-certified figures where ISO 14067 data is not available.

Programme Operators

An EPD is registered with a programme operator — an independent body that maintains a PCR library, manages the critical review process, and hosts verified EPDs in a public registry. Major programme operators include:

• The International EPD System (Sweden): One of the oldest and largest, with global reach and its own PCR for many product categories.
• EPD Norway: Covers construction and building products in Scandinavia.
• ENVIRONDEC: Another common registry, widely used for construction materials.
• NSF International: Active in North America across construction, food contact, and industrial product categories.
• Building Transparency / EC3: Not a programme operator in itself, but an important open database aggregating EPD data specifically for construction materials, widely used by architects and specifiers in the US.
• UL Environment: US-based, with EPDs across electronics, chemicals, and building materials.

The existence of multiple programme operators means that EPDs for the same product type may be registered under different systems. Methodological alignment between systems is improving but not complete; comparing EPDs from different programme operators requires care.

What an EPD Contains

A standard EPD document includes:

• Product description and functional unit: Precisely what is being assessed (e.g., 1 tonne of hot-rolled steel coil, or one smartphone device as sold) and over what reference service life.
• System boundary: Which lifecycle stages are covered. “Cradle to gate” (A1–A3 in EN 15804 terminology) is the minimum for construction materials; “cradle to grave” adds use-stage and end-of-life modules.
• LCA results by impact category: GWP, ODP, AP, EP, POCP, ADPE, ADPF — reported per lifecycle module. The GWP figure is the primary number relevant to carbon accounting.
• Biogenic carbon: Separate reporting of carbon stored in biological materials (wood, paper, natural fibres) is required under EN 15804+A2, reflecting ongoing debate about how to treat temporary carbon storage in wood products.
• Data quality and representativeness statement: The geographic, temporal, and technological representativeness of the underlying LCA data.
• Third-party verifier: Name and affiliation of the independent critical reviewer.
• Validity period: EPDs are typically valid for five years, after which they must be renewed.

How EPDs Relate to CCI Provenance Overrides

The CCI assigns a default score to each product category based on peer-reviewed LCA data and industry averages. This default is intentionally conservative — it represents the higher end of the plausible range for a product made without documented clean energy procurement or verified low-carbon inputs.

A manufacturer or supplier can reduce their product’s CCI score by providing verified primary data through the provenance override process. An EPD is one of the highest-quality inputs accepted for this purpose, because it combines third-party LCA methodology, independent critical review, and public registration. Specifically:

• An EPD registered with a recognised programme operator covering at least the A1–A3 lifecycle modules (raw material extraction, transport to factory, manufacturing) provides a verified cradle-to-gate GWP figure that directly maps to the CCI scope.
• An ISO 14067 or PAS 2050 certified product carbon footprint from an accredited certification body (Carbon Trust, TUV SUD, Bureau Veritas, SGS) is accepted for the GWP indicator.
• A manufacturer’s own Product Environmental Report (PER) is accepted if it follows ISO 14067 or PAS 2050 and has been certified by an accredited third party. Apple’s annual iPhone PERs and Samsung’s Carbon Trust-certified Galaxy reports are examples.

The CCI does not accept self-declared carbon footprints without third-party verification. A manufacturer claiming low emissions without independent review does not qualify for a provenance override.

Limitations of EPDs

Comparability challenges. Even within the same product category, EPDs prepared under different PCRs or with different system boundary choices may not be directly comparable. A construction steel EPD that includes the electric arc furnace scrap melting step but excludes transport emissions is not directly comparable to one that includes transport. PCR harmonisation projects are ongoing but incomplete.

Data vintage. EPDs are typically valid for five years, but the underlying LCA data may be older. A 2024 EPD might rely on 2020 or 2021 inventory data, potentially missing recent changes in grid intensity or process efficiency.

Functional unit specificity. An EPD for “hot-rolled steel plate, 12 mm thickness, structural grade S355” may not apply to a thinner gauge or different alloy used in a different product. Applying EPDs across different specifications requires careful judgment.

Geographic specificity. An EPD based on a European plant’s energy mix and raw material supply chain may not be representative of production in Asia or the Americas.

Cost and access barriers. Conducting a full LCA and preparing an EPD with third-party verification costs between €10,000 and €50,000 depending on product complexity. This is feasible for large volume products and major manufacturers, but impractical for many small manufacturers or low-volume specialty items.

Where to Find EPDs

• The International EPD System: environdec.com — searchable public registry
• Building Transparency EC3: buildingtransparency.org — construction materials focus, US-centric
• INIES (France): national EPD registry for construction products
• Ökobaudat (Germany): national EPD database for building products
• UL SPOT: spot.ul.com — multi-sector EPD and sustainability data
• Manufacturer websites: many large steel producers (ArcelorMittal, SSAB), paper companies (Stora Enso, UPM), and furniture brands (Ikea) publish EPDs directly alongside product specifications

When evaluating an EPD for procurement or carbon accounting purposes, confirm that it is currently valid (within its five-year window), registered with a recognised programme operator, and that the functional unit and system boundary align with the product you are assessing.