EPD data requirements for 2026, clarified
If 2024 felt like alphabet soup, 2026 looks like a tidy pantry. The rulebooks are stable, procurement still favors product‑specific EPDs, and teams that line up data early publish faster with fewer rewrites. Here is the no‑nonsense view of what to collect, how clean it needs to be, and the few shifts to keep an eye on so bids stay eligible and specs stick.
The 2026 baseline in one glance
EPDs for construction products will continue to lean on ISO 14025 and EN 15804 A2. Expect cradle‑to‑gate results for A1 to A3 at minimum, with optional A4 to D as your PCR allows (EN 15804+A2, 2019). Most program operators keep published EPDs valid for five years before renewal, so plan your data cadence accordingly (International EPD System GPI, 2023).
The core data kit to have ready
Think of the EPD like a tax return. If the receipts are tidy, the filing is quick. The essentials most manufacturers need are straightforward.
- Bills of materials per product or formulation at declared‑unit level, including additives and coatings.
- Utility data by site and energy type, including purchased electricity mix and on‑site fuels.
- Production volumes, yields, scrap and rework, and QC rejects for the reference year.
- Inbound transport modes and distances for key inputs, plus outbound packaging.
- Direct emissions and controls where relevant, water use and discharge, and waste by treatment.
- Packaging materials, spares, and consumables that matter at scale.
- Product specs that sell the EPD story: dimensions, density, and installation notes if A5 is modeled.
- Facility, line, and calendar coverage so reviewers can trace every figure to a source.
Data quality rules most teams miss
Primary process data should be less than five years old, and background datasets less than ten years, or the practitioner must justify exceptions in the report text (EN 15804+A2, 2019). Your reference period should represent a normal operating year rather than a pilot run. If the product is new, some PCRs permit a shorter initial window with a required refresh once a full year of production is available.
Facility specificity beats fleet averages
Specifiers are asking where the carbon is actually made. Plant‑level electricity, actual fuel mixes, measured scrap, and line‑specific yields tell a truer story than corporate averages. For categories covered by public procurement rules, facility‑specific EPDs are often the safer choice to keep bids in play.
Packaging, transport, and the silent hotspots
A4 transport can swing results for heavy, bulky products, and packaging sometimes rivals smaller bill‑of‑materials items. Nail down typical shipment weights, truck classes, and distances rather than guessing. Your sales ops system usually knows where pallets go. Use it.
Background datasets and versions matter
Reviewers look for transparent background data choices. Name the database, the version, the geography, and the process IDs inside your LCA model. Keep a short rationale for any proxy material you used. Background data older than ten years will trigger questions unless a PCR grants an allowance (EN 15804+A2, 2019).
Digital EPDs are moving from nice‑to‑have to expected
More program operators are enabling machine‑readable EPDs that feed procurement portals and design tools. That starts with structured product names, clear declared units, and stable SKU or model identifiers. Treat these as master data, not afterthoughts. You will avoid rework when an owner asks for a digital submittal instead of a PDF.
Watch items for 2026
Expect steady PCR refreshes as committees align with EN 15804 A2 interpretations and tighten data quality notes. LEED v5 is progressing and continues to reward product‑specific, third‑party‑verified EPDs that follow the recognized standards. Federal incentives shifted in early 2025, yet state and private requirements keep embodied‑carbon reporting on bid lists.
How to move fast without melting your team
Create a single source of truth for the items above, name one accountable lead, and decide the reference year now. A white‑glove partner can run the outreach, sanity‑check meters, and manage the review loop so your engineers keep building product. This is the boring work that wins specs, definately.
Renewal rhythm that avoids fire drills
Set a five‑year renewal timer on day one and a mid‑cycle data check at year two. That cadence aligns with common program operator validity periods and keeps background datasets within accepted age ranges (EN 15804+A2, 2019; International EPD System GPI, 2023).
Frequently Asked Questions
Which life cycle modules are mandatory for an EN 15804 EPD in 2026?
A1 to A3 are the minimum cradle‑to‑gate modules, with A4 to D added per the PCR and project scope (EN 15804+A2, 2019).
How long is an EPD typically valid before renewal?
Most program operators use a five‑year validity period for EPDs before they must be updated or confirmed (International EPD System GPI, 2023).
How recent must my data be?
Primary process data should be less than five years old and background datasets less than ten years, unless justified in the documentation (EN 15804+A2, 2019).
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.
