EPD market impact in 2026, US and abroad
Specifications are changing faster than inboxes. In 2026, EPDs are no longer a nice‑to‑have footnote. They are the credential that keeps products in the conversation when bids hard‑filter for carbon. The twist is that drivers differ by region, so the commercial playbook must, too.
2026 snapshot: the signal among policy noise
Manufacturers win more often when their products carry current, product‑specific EPDs. LEED v5 was ratified in March 2025 and continues to reward material transparency, which keeps EPDs front and center on complex projects (USGBC, 2025) (USGBC, 2025). At the same time, some U.S. federal climate incentives shifted in 2025, so state and owner requirements matter even more day‑to‑day.
United States: state procurement sets the pace
Colorado requires EPDs for eligible materials on state projects and ties compliance to maximum GWP limits. Design teams have had to specify EPDs since January 1, 2024 (Colorado OSA, 2024). New York requires EPDs for all concrete mixes used on state projects starting January 1, 2025 and applies GWP thresholds by strength class (NYS OGS, 2025). California’s Buy Clean law still mandates facility‑specific EPDs for rebar, structural steel, flat glass, and mineral wool, with Caltrans adding asphalt and concrete EPD submittals on projects bid from February 1, 2025 (DGS, 2025) (Caltrans, 2025).
Europe: CPR and digital product passports reset the rules
The revised EU Construction Products Regulation 2024/3110 entered into force on January 7, 2025, with most provisions applying from January 8, 2026. It introduces digital‑by‑default product information and paves the way for environmental performance declarations embedded in Digital Product Passports as standards update (FPS Economy Belgium, 2025) (FPS Economy Belgium, 2025). The Commission’s first CPR working plan covers 2026 to 2029 and sets the roadmap for harmonized standards and DPP roll‑out (European Commission, 2025).
Database growth shows demand is real
France’s INIES database reported 4,560 FDES and 1,342 PEP on December 31, 2024, a sharp increase driven by RE2020 project requirements (INIES, 2025) (INIES Baromètre, 2025). Germany’s IBU program published more than 840 EPDs in 2024 and has issued over 4,700 since 2012, signaling steady manufacturer uptake across categories (IBU, 2024). ECO Platform lists program‑level totals that illustrate scale. The International EPD System tallied 12,749 EPDs, IBU 2,565, and EPD‑Global 3,716 as of July 1, 2025 (ECO Platform, 2025).
What buyers now expect on bids
Owners and public agencies increasingly ask for product‑specific EPDs with declared GWP that meets a posted limit. Teams want fast access to data packaged correctly the first time, including declared unit alignment, reference service life when required, and verification details. No one has time to chase missing utility months or plant throughput histories in week twelve. Neither do we.
Five moves for 2026
- Map your spec exposure. List product lines that touch state procurements or EU exports, then check where EPDs are missing.
- Choose a partner that takes on data wrangling inside your plants and ERP systems so engineering does not become a bottleneck.
- Prioritize facility‑specific EPDs for materials covered by GWP limits in your target states. Treat industry‑average EPDs as placeholders only.
- In the EU, prepare for digital product passport fields that mirror EPD content. Build clean data now to avoid rework later (FPS Economy Belgium, 2025).
- Track PCR expiries. Renewal windows sneak up and can stall bids if a verifier queue forms.
International work: watch these milestones
LEED v5 is live and shifting credit language, with exam timelines rolling into 2026 for the workforce that services projects (USGBC, 2026). The EU CPR applies broadly from January 8, 2026, with enforcement on environmental performance declarations stepping up from January 8, 2027 as delegated acts and standards land (FPS Economy Belgium, 2025). CSRD coverage has been debated and adjusted, yet supply‑chain requests for product carbon data remain persistent because large reporters still need upstream transparency (Reuters, 2025).
Why this matters commercially
EPDs prevent penalty assumptions in carbon‑managed bids. They also shorten stakeholder debates, since third‑party verified numbers settle arguments about what to count and how. The cost of creating strong EPDs is routinely outweighed by a single mid‑sized project win. Reliable cost averages are hard to pin down because scopes differ, but the revenue upside is visible in pipeline velocity when submittals stop getting bounced.
What “fast” looks like now
Speed comes from ruthless data collection inside your walls and clear project management, not from cutting corners in the LCA. Expect a partner to interview line staff, reconcile utility bills, and align BOMs to PCR rules, then publish with the operator your market prefers. If a team hands you a template and leaves, the schedule will slide. It always does, untill someone does the heavy lifting.
The takeaway for 2026
Do not wait for a universal rule to force your hand. State policies in the U.S. and the EU’s CPR timeline already make EPDs the ticket to play. Get your data house in order, publish product‑specific EPDs, and keep them current. The market is rewarding manufacturers who make carbon accounting easy for everyone else.
Frequently Asked Questions
Which U.S. policies in 2026 most directly trigger EPD needs on public projects?
Colorado’s Buy Clean policy requires EPDs and sets GWP limits for eligible materials on state projects (Colorado OSA, 2024). New York requires EPDs for concrete on state projects from January 1, 2025 with strength‑based GWP limits (NYS OGS, 2025). California mandates facility‑specific EPDs for steel, flat glass, and mineral wool, with Caltrans also collecting asphalt and concrete EPDs on projects bid from February 1, 2025 (DGS, 2025) (Caltrans, 2025).
What EU change in 2026 affects product data planning the most?
The revised Construction Products Regulation applies broadly from January 8, 2026 and introduces digital‑by‑default product information that underpins future Digital Product Passports tied to updated standards (FPS Economy Belgium, 2025).
Is there evidence of growing demand for EPDs in Europe?
Yes. INIES reported 4,560 FDES and 1,342 PEP at year‑end 2024, up strongly year on year, driven by RE2020 (INIES, 2025). IBU issued over 840 EPDs in 2024 and has passed 4,700 total since 2012 (IBU, 2024). ECO Platform reports five‑figure EPD totals across major programs, including 12,749 at The International EPD System as of July 1, 2025 (ECO Platform, 2025).
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.
