EPD usage

To date, manufacturers are not obliged (mandatory by law) to provide EPDs. 
But, the market increasingly regulates the use of EPDs in various applications itself.

Upcoming regulations and directives for EU domestic and foreign organisations:

• European Green Deal; an initiative that should make Europe the world’s first climate-neutral continent

• European Circular Economy Action Plan

• EU Product Environmental Footprint (PEF), with product specific category directives (e.g. Battery, Food, 
Packaging, a.s.o.)

• Directive of EU Parliament and the Council on Corporate Due Diligence and Corporate Accountability (originally 
only about Human Rights, but now includes embodied carbon)

• EU Level(s); the European framework for sustainable buildings

• EU CE(Conformite Europeenne)-mark to ensure to EU consumers products' health, safety, and environmental 
safety.

• EU Carbon Border Tax tied to Imports; one of several financial mechanisms that the European Commission is 
considering as part of the European Green Deal.

Market regulation (semi-mandatory/bonus-malus) in place as of today:

• Green Building Schemes (BREEAM, LEED, DGNB, WELL, a.s.o.)

• LCA and Building level LCA
e.g. Netherlands, Belgium, Norway, Sweden, Indonesia.

• (Green) Public Procurement
e.g. Sweden (Trafikverket, Boverket) and Italy (large retailers & public organisations such as ENEL)

• Supply chain management (e.g. EcoVadis, SEDEX)

• Green bonds (e.g. via ISO-standards)

Building level LCA's are increasingly being be mandated (market regulation) when trying to address the topic 
of embodied carbon in buildings by public and private actors, esp. in the Nordics and Western-Europe.

EPDs provide the product-specific environmental performance data that can be used when conducting the 
whole building LCA.

Building Level LCA is closely linked with voluntary green building schemes, but there is no doubt that this method 
will increasingly be mandated by policy developers working on future directives and regulations.

Eg. in Sweden we see a national law coming in place that may require any building coming to market from 2022 to 
have a building level LCA. For additional information (in Swedish) on expected mandatory Building LCA requirements 
in Sweden, please visit regeringen.se and boverket.se

European Commission's Level(s) framework for sustainable buildings

In addition, the European Commission's Level(s) framework, which is a new European approach to assess and report 
on the sustainability performance of buildings, throughout the full life cycle of buildings will push for harmonization 
on EU level.

Using existing standards, the Level(s) framework with its indicators provides a common language for building 
sustainability, which can be used directly on building projects and portfolios, or as a basis for other initiatives, policies, 
schemes, and actions, to include life cycle thinking and circularity.

By using EPDs, the organisation could gain a competitive edge in green public procurements.

There are three main methods on how to use EPDs in public procurement. Please note that this information is 
provided as examples and that no liability is taken for the correctness of the information for specific cases or 
markets:

• To get information on the environmental impact of the goods and serviced being procured can be seen as the 
first step in greening the procurement activities. Knowledge about the impact of the subject matter is vital in 
order to be able to put down relevant GPP criteria in the tendering documents. EPDs can therefore give very 
useful input to GPP, either in the market analysis or as a first step in greening the GPP.

• As the EPDs contain information on the products' environmental impact from a life cycle perspective, the EPD 
can be used to verify compliance provided that the environmental requirements put in the tendering documents 
is information that can be found in an EPD.

• Information in EPDs within the same product group and based on the same PCR can also be used to compare 
products from an environmental point of view and also to reward the environmentally best product. This must be 
done according what is allowed in the legislation and the reward criteria must be transparent and non-discriminatory.

Watch info video on public procurement and EPDs prepared by the Delegationen för cirkulär ekonomi (in Swedish).

In marketing, many organisations want to make claims of their product´s environmental performance, 
especially if it is superior compared to other similar products on the market.

In order not to violate national marketing acts and international codes of conduct, such as the International 
Chamber of Commerce (ICC) rules on advertising and marketing communications, these organisations must be 
able, on any demand, to demonstrate proof of different aspects of the environmental claims they are using.

If the organisation has developed an EPD for the product, they indeed have a very comprehensive documented to 
refer to. The EPD will most likely meet all requirements that might be raised by any external party which would like 
to argue about any possible deficiencies in the organisation's environmental claims.

Can you benchmark products' environmental impacts against e.g. peers' that also have EPDs? 
Definitely, but with caution!

Oh, and no, EPDs do not include such environmental claims!
You will need to do the benchmarking...

Comparing your own environmental performance of your products and services over time to industry bests and best 
practices from other companies enables you to see how you perform against your peers and be prepared to meet 
growing market demands for product sustainability.

Today, LCA comparisons on product level, assembly level and whole buildings are (common) practice in the 
construction sector. But, unfortunately are we during such comparisons - still - forced to a large extent use generic 
datasets because of the simple lack of specific (EPD) product data. Manufacturers are now requested by architects, 
developers and so on to fill this data gap. Simultaneously, we see that academia are also progressing and experiment 
with machine learning algorithms for embodied carbon calculations and predictions. But, to properly test such algorithms 
they also crave for more specific data as feedstock.

When you start comparing you will need to follow some rules, and be aware of the peculiarities that come with 
comparing EPDs. In particular when the used EPDs are provided by different EPD programme operators. The PCRs of 
the different EPD programme operators that are used during the LCA most likely differ to some extent (also valid for 
EN15804 standard compliant EPDs) because we as programme operators need to provide our interpretation of the 
standards to the LCA practitioners where these standards are unclear. These interpretations are in our case developed 
in a multi-stakeholder engagement process and the final result is made available via the PCRs. You now understand that 
all PCRs for similar products are not necessarily fully aligned. One known and well-described example for deviations - est. 
10-20% variations in impact results - is the allowance (or not) to use different LCI/LCA background databases.

Examples of EPD benchmarking features/ solutions EC3 tool, EPD Analyzer, Planetary tool

And, in case you want to dive a bit deeper, we recommend to read a scientific paper on implications for environmental 
benchmarking in LCA published by two of the EPD Secretariat staff members, who are also employed as researchers 
at IVL Swedish Environmental Research Institute.

Ecodesign, or Design for Environment (DfE), eco-design or, more generally, Environmental design, is the concept 
of taking environmental issues into consideration when designing and developing new products, or when 
updating existing products.

EPD, and the underlying life cycle assessment (LCA) study, may be used as a way to measure impacts and avoiding 
sub-optimization.

An organization making use of EPDs can easily track and report on improvements in the environmental performance 
of its products, both internally and externally. In this way, EPDs can serve as a vital supporting component to serve 
as an indicator in its work on product development on what is most relevant to focus on.

The LCA methodology used for EPDs in the International EPD System gives a benefit for using recycled material and 
for designing products that may be reused or recycled, thus steering towards products that are part of a circular 
economy.

Value chain collaboration with LCA-data may lead to process development.

EPDs are developed for specific product categories making use of internationally standardized methods 
for definition of all sub-categories of products according to the UN system called Central Product Classification 
(CPC). Therefore EPDs can be established for all types of products wherever they might be in a hierarchy of product 
categories.

Following this EPD´s can be developed for all types of products in a supply chain – from the very initial stage with 
acquisition of raw materials to subsequent stages in the refinement of these raw materials to sub-components 
delivered to the final manufacturing.

As consequence, separate EPDs in a supply chain can be added up together to provide a final manufacturer with 
a complete information of the environmental performance of a semi-manufactured product as an input to their 
overall manufacturing process.

By using EPDs, an organization can identify, control, monitor and evaluate the environmental performance 
from a life cycle perspective and also communicate the result to different stakeholders.

EMS such as ISO 14001 and EMAS require the organization to identify and consider the environmental impacts 
from its operational planning, activities, products and services. They also require the organization to monitor, 
measure, analyze and evaluate its environmental performance, which needs to be communicated both internally 
and externally. The organization shall also see to that the information is relevant and reliable. One way to identify 
any organization’s significant environmental aspects is to make use of LCA methodology, to which EPDs are very 
useful as they can be used to communicate continuous environmental improvement of goods and services over time 
following measures taken to make its product more environmentally-effective.