Good Enough Reporting Is Over for Data Center Builders

From nice to have to non-negotiable

Three signals hardened in 2024 and 2025. California requires EPD submittals for asphalt, concrete, and more on state transportation projects, with updates posted August 21, 2025 (Caltrans, 2025). Colorado set maximum GWP limits and made product-specific Type III EPDs mandatory for eligible materials on state projects in 2024 (OSA, 2025). New York State made concrete EPDs and strength-specific GWP caps mandatory on qualifying state work starting January 1, 2025 (OGS, 2025).

Why data centers feel it first

Data centers concentrate carbon in a small set of materials. Steel, concrete, glass, aluminum, insulation, cabling, and MEP-heavy packages dominate early-phase buys. LEED v5 moved embodied carbon to a prerequisite for BD+C projects, forcing teams to quantify A1 to A3 impacts for structure, enclosure, and hardscape before points even start (USGBC, 2025). That puts EPDs on the critical path, not the marketing plan.

Owners are writing it into contracts

Colocation and hyperscale owners now expect transparent product carbon. One large operator updated contractor templates in 2024 to reserve the right to request product-level embodied carbon data in the form of EPDs or LCAs, and to engage embodied carbon consultants from design through construction (Equinix, 2025). Microsoft, Meta and others publicly target low carbon concrete and near-zero steel in new builds, which cascades EPD and LCA asks down the supply chain (Microsoft, 2024; Meta, 2024).

The EU’s spillover pressure

The recast Energy Efficiency Directive requires data centers in Europe above 500 kW to report performance annually to an EU database, with first reports due September 15, 2024 and May 15 in subsequent years (European Commission, 2024). While separate from material EPDs, it normalizes audited disclosures and tight KPI tracking, which buyers then expect from suppliers on embodied impacts too (EUDCA, 2025).

What mandatory in practice looks like on a bid

Here is the pattern we keep seeing. The RFP cites LEED v5, a state Buy Clean guideline, or both. Submittals require current, product-specific Type III EPDs that match the specified PCR and show GWP at or below a posted threshold. Teams screen options in EC3 or a similar database. Late EPDs stall submittals, and the package moves to a ready competitor.

EPDs, LCAs, HPDs, clarified

An EPD is the summarized, third-party verified label for a product’s life cycle impacts, most visibly GWP. The LCA is the study behind that label, aligned to ISO 14040 and 14044. HPDs document material health and hazard disclosure. For data center shells and fit-out, EPDs and LCAs drive selection and scoring. HPDs can matter for interiors and staff spaces, but they rarely unlock embodied carbon compliance.

Timelines are the new price point

State thresholds, LEED v5 prerequisites, and owner policies squeeze schedules. Reliable cost averages are hard to pin down because scopes vary, but we repeatedly see that one mid-sized specification win can repay an EPD effort. Slow credentialing, by contrast, drags procurement and adds carrying costs to the whole project. Speed, not bargain hunting, protects the bid clock.

Five moves to stay specification-strong

1. Map your catalog to likely PCRs, including any generic construction PCRs, and note expiries so renewals do not surprise you.
2. Prioritize plant- or product-specific EPDs for high-volume SKUs tied to steel, concrete admixtures, rebar, aluminum, glass, insulation, cable trays, racks, and switchgear.
3. Standardize utility and mass-balance data pulls for one reference year across sites, so the LCA can flow with fewer emails and less downtime.
4. Publish with the program operator your customers prefer, and keep PDFs and machine-readable data handy for database upload.
5. Recheck your submittal set 6 months before big pursuits, so impending expiries do not trip you up.

Choosing a partner without headaches

Ask who leads the data wrangling inside your plants, who coordinates multi-site pulls, and who keeps PCR alignment straight. Good partners minimize your engineers’ time, anticipate expiring rules, and deliver third-party verified LCAs and EPDs ready for Caltrans, Colorado OSA, and NYS OGS screens. A spreadsheet jockey will not cut it, you need a white-glove project manager who lives in this process.

The spec is moving, keep pace

Data center work now treats embodied carbon like uptime. Document it, prove it, and hit the posted limits. Teams that show up with current EPDs and dependable LCAs win time, win points, and often win the scope. Everyone else is stuck refreshing inboxes and hoping for waivers that might never come. It is definately avoidable.