Secondary Data: Hidden Risk in EPD Projects
Life-cycle databases are fantastic for idea-stage modeling, but stake your final EPD on generic proxies and you invite credibility gaps, lost bids, and frantic last-minute data chases. The smartest manufacturers swap proxy shortcuts for laser-targeted primary data, without burying their engineering teams in spreadsheets. Here’s why.
Secondary data, defined in plain English
Think of secondary data as a stock photo: handy, quick, and rarely an exact match. In LCA terms it covers off-the-shelf datasets from ecoinvent, GaBi, or national hubs when you lack site measurements. Program operators allow them, yet every proxy adds swing to your impact scores.
The math behind the wiggle room
A 2024 cross-program study on triple-glazed windows found climate scores shifting by more than 10 % solely from database choice (Konradsen et al., 2024). That margin can drop you from first to fourth on a low-carbon tender leaderboard.
Regulators are tightening the screws
New JRC Data Quality Rating rules will require full scoring of both primary and secondary datasets for EU-bound EPDs as early as 2026 (JRC DQR Rules, 2025). In the US, EPA is updating core electricity and transport inventories after flagging “numerous data gaps” due August 2025 (EPA, 2025). Translation: reliance on out-of-date proxies will soon fail reviews.
Primary data: heavier lift, bigger payoff
Metered energy, plant-specific recipes, and real logistics unlock bulletproof declarations. They also reveal true hot spots your R&D team can fix, instead of masked averages that hide inefficiencies.
Big company, bigger headache
If you run multiple sites, just herding bills, resin specs, and maintenance logs can stall a project for six months. When engineers juggle core work and EPD spreadsheets, deadlines slip and morale tanks. The opportunity cost is glaring.
The case for outsourcing the hunt
A white-glove EPD partner spends every hour of every day ripping data from ERP silos, lab LIMS, and plant historians. They know which procurement manager holds the missing additive spec and how to translate it into EN 15804-ready entries. You gain speed, reliablity, and a calmer calendar.
Wrap-up: choose data that wins specs
Secondary datasets will always have a place for scoping, but today’s competitive bids reward declarations underpinned by credible, plant-level numbers. Offload that primary data chase to specialists, keep your engineers building better products, and watch the win rate climb.
Frequently Asked Questions
What exactly counts as primary data for an EPD?
Direct measurements or production records from the specific facility—utility meters, ingredient invoices, lab-tested yields—collected for the period defined by the PCR.
How much secondary data is still allowed after 2026?
Regulations don’t ban it, but both EU and US guidance now demand documented data-quality scores and justification if robust primary data was feasible (JRC DQR Rules, 2025).
Will switching to primary data delay my EPD project?
Not if a specialist manages the data pull. Modern templates and API links often cut lead time versus an internal scramble, despite the richer dataset.
Do proxies ever make sense?
Yes—for upstream commodities outside your control or early design iterations. Just flag them clearly and update once real numbers become available.
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
