Does LEED v5 still reward product-specific Type III EPDs or did the system change to only whole-building LCA?

LEED v5 keeps and expands materials transparency. It adds an embodied‑carbon prerequisite for structure, enclosure, and hardscape, while product‑specific EPDs remain valuable pathways within materials credits (CAGBC, 2025).

Are industry-average EPDs acceptable for state Buy Clean projects in 2025?

Generally no. California specifies facility‑specific, third‑party verified Type III EPDs for eligible materials and rejects industry‑wide EPDs for compliance purposes (DGS, 2025).

If we cannot gather a full year of data, can we still publish?

Yes. A prospective EPD is possible for new products using several months of production data, then updated when a full reference year is available. Confirm acceptance with your chosen program operator and the project’s submittal rules.

From Steel to Sealants: EPDs Decide Data Center Specs

Why 2025 is the tipping point

Data center electricity demand is accelerating and owners are under pressure to prove material impacts with numbers, not promises. The IEA projects data center electricity use to more than double this decade, with AI workloads driving much of the growth (IEA, 2025) (IEA, 2025). Bigger programs mean tighter procurement rules.

At the same time, embodied‑carbon policies and rating systems leaned into EPDs. LEED v5 introduces an embodied‑carbon prerequisite and expands materials transparency, signaling mainstream expectations for product‑specific declarations (CAGBC, 2025) (CAGBC, 2025).

Public buyers already require EPDs

California’s Buy Clean program requires facility‑specific, third‑party verified EPDs and sets GWP limits for steel, rebar, flat glass, and insulation, updated for 2025 (DGS, 2025) (DGS, 2025). Colorado mandates EPDs in bid documents for eligible materials on state projects beginning January 1, 2024 (OSA, 2024). New York requires EPDs for all state concrete mixes from January 1, 2025 (NYS OGS, 2025).

Private data center programs frequently mirror these requirements. Many owners now ask for product‑specific Type III EPDs in spec sections for concrete, steel, and envelope packages, often using EC3 to check market options (Building Transparency EC3, 2025).

Who is most at risk of being value‑engineered out

Ready‑mix concrete and cementitious binders. High mass and high scrutiny, with thresholds tied directly to EPD‑reported GWP in multiple jurisdictions (NYS OGS, 2025).
Structural steel and reinforcing bar. California sets category‑specific limits and demands facility‑specific EPDs, not industry‑average declarations (DGS, 2025).
Envelope insulation and air‑barrier systems. Insulation is explicitly scoped in California updates and shows up in LEED v5’s prerequisite materials list (CAGBC, 2025).
Flat glass and curtain wall systems. Public buyers require EPDs and design teams benchmark GWP early to lock façade choices.
Raised access floors. Data center mainstays where submittals increasingly ask for product‑specific EPDs to avoid default penalties.
Firestopping, intumescent coatings, and sealants. Often overlooked, yet easy wins for credits and procurement checklists when a verified EPD exists.
Aluminum extrusions and cladding. Recycled content claims rarely land without an EPD to quantify benefit.
Precast and tilt‑up wall panels. Large volumes magnify the cost of lacking an EPD during carbon budgeting.

What counts as a “good enough” EPD for spec writers

Aim for a product‑specific, Type III, third‑party verified EPD, aligned to ISO 14025 and ISO 21930 or EN 15804. Facility‑specific data is favored in policy language. Industry‑average EPDs help with early modeling but rarely satisfy submittals where limits apply.

If you are new to market, a prospective EPD can bridge the gap using several months of production data, then be updated after a full reference year. Age matters less than validity; an older EPD still earns the tick unless it is near expiry.

Picking the right PCR without drama

A PCR is the rulebook of Monopoly. Ignore it and the game falls apart. The practical move is to scan competitor EPDs in EC3, then choose the same or a clearly compatible PCR. That keeps apples with apples and avoids surprises in comparative GWP results.

Why EPDs change the sales math in data centers

Without an EPD, design teams must use conservative default factors and sometimes add percentage buffers, which can make your product look heavier than it is. With an EPD, you remove the penalty and keep price from becoming your only lever. One mid‑sized shell or fit‑out win can cover the credentialing exercise, even though reliable cost averages vary by scope and geography.

Avoid the internal stall points

Most delays happen long before modeling. The slow part is wrangling utility bills, material inputs, and yields across plants. Choose an LCA partner who takes on the data collection work inside your organization, keeps a tight project plan, and publishes through the program operator of your choice in the U.S. or EU, such as Smart EPD or IBU. Your spec chances definately improve when submittals land fast and clean.

A 45‑day plan that survives real life

Week 1 to 2: Lock product list, facilities, reference year, PCR, operator, and intended markets. Confirm whether a prospective EPD is needed for any new SKU.

Week 3 to 4: Centralize data pulls from production, QA, purchasing, and energy. Close gaps with auditable assumptions agreed with the verifier.

Week 5 to 6: Complete LCA modeling, internal QA, and third‑party review. Prepare a one‑page submittal summary with declared unit, system boundary, and GWP headline. Publish and upload to EC3.

The bottom line for 2025 specs

Demand for capacity is climbing while policies and LEED v5 normalize embodied‑carbon accounting. Suppliers who show up with clean, comparable EPDs win earlier in design and stay in the bid set longer. Get your declarations in place now so the next RFQ reads like a green light, not a red card.