Where EPDs Decide Who Wins Public Bids
Across the US and Europe, public buyers have put Environmental Product Declarations on the must-have list. Miss one form and you are out of the running before price ever enters the room. Below is the current lay of the land, what triggers the mandate, and how big the projects must be.
Why public agencies suddenly care about cradle-to-gate data
Budgets are getting tied to climate goals. Legislators realised that every ton of steel, yard of concrete, or pane of glass they buy locks in carbon for decades. EPDs offer a comparatively cheap way to prove improvement without redesigning whole buildings. No surprise the rules exploded in the last two years.
United States: four states set the pace
California
Buy Clean California Act covers structural steel, rebar, flat glass, and mineral-wool insulation on state contracts that run 175 working days and top US $1 million. Caltrans adds asphalt and concrete from February 1 2025. Facility-specific EPDs must meet GWP caps before installation (PCC §3503, 2024; Caltrans FAQ, 2025).
Colorado
Since Jan 1 2024, any state-funded project ≥ US $500,000 needs EPDs for seven “eligible materials” and has to prove they stay under Office of the State Architect GWP limits (OSA policy, 2025).
New York
Mandatory from Jan 1 2025. Building contracts ≥ US $1 million that place ≥ 50 yd³ of ready-mix (or DOT jobs ≥ US $3 million and ≥ 200 yd³) must submit mix-specific concrete EPDs that beat regional GWP benchmarks (NYS OGS, 2024).
Washington
The Buy Clean / Buy Fair Act starts with state buildings > 100,000 ft² bid after July 1 2025. Contractors must upload product EPDs for at least 90 % of the spend on concrete, steel, and wood and later hit to-be-set GWP limits (HB 1282, 2024).
Worth watching: Oregon DOT already collects asphalt and concrete EPDs on pilot bids; Minnesota, Illinois, and Maryland have study bills in committee but no hard start date yet.
Europe: early adopters tighten the screws
Netherlands
Every Rijkswaterstaat tender scores bids with the Milieu Kosten Indicator, a cost adder based on full project LCAs. EPDs are obligatory inputs under the updated Protocol 4.1 from Jan 1 2025 and affect all civil-works bids, no minimum value (Rijkswaterstaat, 2024).
Sweden
A climate declaration, built from product EPDs or Boverket generic data, is required for any new building that needs a permit since 2022. Public developers now add bonus points for project bids that swap generic datapoints with product-specific EPDs, ahead of a national GWP limit arriving in July 2025 (Boverket, 2025).
Denmark
From 2023 all new buildings > 50 m² must submit an LCA. Ones > 1,000 m² cannot exceed 12 kg CO₂e/m²/yr today and will drop to 7.1 kg in 2025. The national guide states that product EPDs override default data and can shave four to six percent off the CO₂ tally (BR 18 guide, 2025).
Norway
A 30 % environmental weighting is compulsory in public procurement since 2024. State road and rail agencies grant bid credits when project-specific EPDs beat EPD-Norway averages, effectively turning carbon into a line-item discount (EPD-Norway, 2024).
Common threads manufacturers must note
- Project value triggers sit between €500k and US $1 million in most laws.
- Facility-specific EPDs trump industry-average in every jurisdiction listed.
- Agencies are phasing in GWP caps two to three years after first asking for EPDs.
- Missed EPD uploads already lead to withheld payments (Caltrans withholds up to US $6,000 per missing file).
The hidden cost of delay
Waiting until a tender drops means working nights to gather twelve months of utility bills, waste logs, and transport tickets. EPD lead times still average six to nine months with conventional consultants. That gap can kill your bid pipeline for an entire fiscal year.
Your next move before the RFP lands
Line up internal data owners now, pick the PCR competitors use, and schedule LCA modelling long before bid day. Securing an EPD early changes you from reactive bidder to spec-setter, literally locking rivals out of the conversation.
Regulation will only ratchet tighter. Get ahead while paperwork, well, is still just paperwork.
Frequently Asked Questions
Do facility-specific EPDs really matter if the law allows industry averages?
Yes. Every state and country above either scores bids or sets GWP caps. Facility-specific EPDs almost always land 10-30 % below the generic baseline, which can decide the award.
How quickly can a manufacturer produce compliant EPDs for multiple plants?
With streamlined data capture and an experienced LCA team, three to six months is now realistic for a portfolio of plants. Traditional timelines still hover near a year.
Are recycled-content tweaks enough to pass upcoming GWP limits?
Often no. New York’s 2027 concrete cap is 275 kg CO₂e/yd³ for low-strength mixes—roughly 25 % below current regional averages—so mix design, energy sourcing, and logistics all need attention (NYS OGS, 2024).
Do European carbon declarations replace CE marking?
No. CE deals with product safety and performance. EPDs quantify environmental impact and will sit inside the future Digital Product Passport under the revised EU Construction Products Regulation.
About the Author
John brings a clear, research-driven perspective on the EPD, LCA and HPD space and keeps a close pulse on environmental trends and standards in North America, helping clients understand where the industry is heading and how to get there.
