EPD Expired, Recipe Unchanged: What Now

Validity is a clock, not a vibe

Five years is the norm. Program operators set the date on the PDF and it typically runs five years from verification and publication, not from the data year (IBU, 2025) (IBU, 2025). The International EPD System notes the validity date is normally plus five years from verification, printed on the declaration itself (EPD International FAQ, 2025) (EPD International FAQ, 2025).

The 10 percent tripwire

Even inside that window, an EPD is not fire‑and‑forget. If any declared indicator worsens by 10 percent or more over the reported stages, the EPD must be updated during its validity period. Annual internal follow‑up is expected to catch these shifts (EPD International, 2025) (EPD International, 2025).

Why expired EPDs stall bids

Public owners increasingly screen for current declarations. California’s Buy Clean implementation guidance tells agencies to accept only EPDs that are facility specific, third‑party verified, tied to an applicable PCR, and valid at installation. Private owners and LEED v5 projects also prefer up‑to‑date, product‑specific disclosures because old numbers create submittal friction. It is paperwork as gatekeeper, like showing an out‑of‑date passport at the terminal.

“But our process barely changed” is not a defense

Many tiny moves can add up. A new compressor, a supplier shift on a key resin, or a tariff‑driven route change can ripple through A1 to A3. Grid factors and background datasets also evolve, so a stable recipe can still produce different results after the model is re‑run. Think of it like a favorite playlist that sounds different after a streaming codec update.

Renewal, re‑verification, or full refresh

If the recipe, plants, and energy mix stayed within the 10 percent guardrail, a re‑verification using the existing background report is often enough. If a PCR has been revised, plan to align at renewal. If the product or a plant changed materially, a full recalc is safer than trying to patchwork edits. The goal is a credible, audit‑proof PDF that mirrors reality and keeps bids moving.

A fast triage you can run this week

Use a short checklist to decide if you need an early update.

• Scan utility bills against the EPD reference year, note big deltas.
• Check any BOM substitutions, recycled content shifts, or supplier swaps.
• Confirm plant coverage still matches how you ship.
• Recalculate if any declared indicator likely crosses the 10 percent line.
• If nothing material changed, schedule re‑verification before the validity cliff.

Timelines that protect revenue

Aim to kick off renewal 6 to 9 months before the printed date. That buffer absorbs verifier questions and avoids the bidding dead zone where your EPD is days from expiry. If a high‑stakes RFP looms, prioritize the SKUs that appear in those bid schedules first, then cascade to the long‑tail portfolio.

What submittal reviewers actually look for

They expect a product‑specific Type III EPD that cites the governing PCR, lists the correct plant, displays the validity date clearly, and is easy to download without logins. Add a short memo that maps the declared unit and GWP figure to the exact bid line item. Small touches save days of back‑and‑forth and avoid a last‑minute scramble that no one enjoys.

Bottom line for mature, slow‑changing lines

Old processes do not grant amnesty. Five‑year validity and the 10 percent rule draw the real boundaries for when to refresh, when to re‑verify, and when to rebuild the model (IBU, 2025) (EPD International, 2025). Keep a light annual check, plan renewals early, and your enviromental proofs keep winning attention instead of raising eyebrows.