GPP Rules That Demand Your Product’s EPD
Public buyers are tightening the screws: no verified Environmental Product Declaration, no seat at the table. From Brussels to Sacramento, tenders now spell out "Type III EPD required" next to price and delivery terms. Miss that line and your bid lands in the recycle bin before anyone looks at your engineering specs.
Green Public Procurement in one minute
European public authorities alone spend about €2 trillion each year—roughly 14 % of the bloc’s GDP—on contracts (European Commission, 2024). Green Public Procurement (GPP) uses that spending power to push environmental performance. The fastest way for a buyer to prove a product’s footprint is to ask for a third-party verified, PCR-based Environmental Product Declaration.
Why EPDs hit the sweet spot for contracting officers
• Standardised: ISO 14025 gives every evaluator the same rulebook.
• Comparable: Results come in a tidy table, ready for spreadsheet scoring.
• Auditable: Independent verification calms headline-averse risk teams.
EU criteria: voluntary on paper, decisive in practice
The European Commission has drafted GPP criteria for dozens of product groups. In the Office Building Design set, the “comprehensive” level tells procurers to specify construction materials backed by a Type III EPD. Member-state portals routinely copy-paste that wording into real tenders, turning a “nice-to-have” into a gatekeeper overnight.
Netherlands: MKI scores powered by EPD data
Rijkswaterstaat now weights bids with the Milieukosten-indicator (MKI). Contractors must calculate MKI values in DuboCalc, which pulls inventory data from the National Environmental Database—populated almost entirely by verified EPDs (Rijkswaterstaat, 2024). No EPD, no MKI, no contract.
United States: Buy Clean waves the flag for disclosure
California’s Buy Clean Act sets hard GWP limits for key materials and accepts only product-specific EPDs as proof (DGS, 2024). The U.S. General Services Administration has followed suit: its $2.15 billion low-embodied-carbon program demands third-party verified EPDs at bid time (GSA, 2025).
What this means for manufacturers
Procurement teams are writing EPD clauses faster than many factories can run their next batch. Lag and you risk late-night scramble bids or, worse, disqualification. Get ahead by:
- Mapping which product lines face public-sector demand in the next 12 months.
- Pulling primary data now—energy meters, material bills, transport legs—before R&D calendars jam up.
- Choosing partners that shoulder the data wrangling and liaise directly with program operators so your engineers stay on the line, not in meetings.
Spotting an EPD trigger in a tender
Look for phrases like “Type III Environmental Product Declaration,” “EN 15804 compliant LCA,” or “cradle-to-gate GWP ≤ X kg CO₂e.” They all translate to the same thing: get your declaration published or step aside.
The simple truth
Green Public Procurement is no longer a policy side note. It is a pass-fail filter. Show up with a rock-solid, third-party verified EPD and your bid sails through compliance checks while competitors scramble. Delay, and you start every tender ten yards behind the starting line.
Frequently Asked Questions
Do EU GPP criteria legally force me to have an EPD?
The criteria themselves are voluntary, but national or local buyers often copy them directly into mandatory tender documents. In practice, that makes an EPD a de facto requirement for many public projects.
Can I submit an industry-average EPD to meet Buy Clean California limits?
No. The Department of General Services requires a product-specific, third-party verified EPD and compares its cradle-to-gate GWP to the published limits (DGS, 2024).
Will one EPD cover every public procurement market?
A single EPD typically satisfies multiple jurisdictions, but check that it follows the right PCR and verification type. Some buyers request additional modules (for example, A4–A5) or facility-specific data.
What happens if my EPD numbers exceed a tender’s GWP cap?
You can still bid, but you must offer design optimisations, sourcing changes, or offsets that bring the declared GWP below the cap. Without that, evaluators will mark your offer non-compliant.
About the Author
Eric works at the intersection of sustainability, regulation, and business strategy, helping manufacturers navigate the evolving landscape of EPDs and LCAs. Having spoken with hundreds of teams across North America, brings a deep understanding of what drives ROI, what regulators are asking for, and how companies can stay ahead with smart, scalable approaches to environmental reporting.
