EP Regulations: What 2025 Means for Manufacturers
Carbon rules are changing faster than a TikTok trend. Federal pullbacks in Washington sit beside ambitious state mandates and fresh EU directives. If your product data lives in spreadsheets, you might feel the squeeze before year-end.
The EU’s New Construction Products Rulebook
The recast Construction Products Regulation entered into force on 7 January 2025 and hard-wires sustainability data into each product’s Digital Product Passport (European Commission, 2025). Expect architects to scan a QR code and pull your EPD on the spot. No passport, no spec.
CSRD: Fewer Companies, Same Spotlight
February’s Omnibus package slashed the Corporate Sustainability Reporting Directive’s scope to firms with over 1,000 employees, yet it still demands product-level impact data from those giants (EC, 2025). If you supply them, your EPD numbers will surface in their public filings—even if you remain below the headcount cutoff.
Federal Retreat, State Surge in the U.S.
With large chunks of the Inflation Reduction Act rolled back, federal Buy Clean momentum stalled. Meanwhile, California will tighten GWP ceilings for steel and insulation on 1 January 2025 (DGS, 2025) and New York makes concrete EPDs mandatory the same day (NYS OGS, 2023). Bids lacking compliant declarations are simply tossed.
LEED v5 Turns Up the Volume
The 2024 draft rewards buildings that cut embodied carbon by at least 10 % compared with regional baselines (USGBC, 2024). Project teams will chase products carrying transparent, third-party-verified EPDs to unlock points—missing documentation equals missed credits.
PAS 2080 Spreads Beyond Infrastructure
The 2023 revision widens the UK standard’s net-zero lens to cover all built-environment products (ICE, 2023). If you export façade panels or MEP gear, expect clients to ask whether your EPD aligns with PAS 2080 life-cycle rules.
Three Moves to Stay Ahead
- Centralize raw data now. Pull 2024 utility bills and volume records before teams change and memories fade.
- Audit PCR timelines. A recertification crunch looms as many PCRs expire in 2026; renewals will need the updated versions.
- Choose partners who chase the data for you. The hidden cost is the internal scramble, not the LCA fee. Insist on a process that spares your R&D talent from month-long spreadsheet marathons.
The Takeaway
Regualtions may diverge on paper, yet they converge on one demand: credible, current, cradle-to-gate numbers. Lock in your data discipline now and tomorrow’s rule changes feel more like a calendar reminder than a crisis.
Frequently Asked Questions
Do I need a new EPD because the EU CPR recast went live?
Not immediately. Existing EPDs remain valid until their five-year renewal but the next edition must plug into the Digital Product Passport format.
Our company is under 1,000 employees—does CSRD affect us?
Indirectly. If you sell to a CSRD-covered customer, they can request your product GWP data for their supply-chain disclosures.
Will California accept industry-average EPDs in 2025 bids?
No. The Buy Clean California Act now requires facility-specific EPDs that fall below the updated GWP thresholds.
How often will LEED v5 projects ask for updated EPDs?
LEED accepts EPDs published within the past five years, but designers prefer newer documents to show progress on emissions.
Can PAS 2080 verification replace an EPD?
PAS 2080 guides carbon management across a project. It does not substitute for the ISO-based EPD needed at product level.
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
