Embodied Carbon: The New Hyperscaler RFP Filter
There is a new pre-qualification test sitting inside data center RFP portals. It does not argue, it just sorts. If your concrete, steel, switchgear, cable trays or insulation lack clear, comparable EPDs with the right PCR and plant data, the bid quietly drops out of view. Legacy suppliers feel it as fewer callbacks, not a debate on price.
The quiet shortlist killer
Embodied carbon is acting like the spam filter of procurement. Buyers set a few rules, upload thresholds, and let the system screen. If a product has no third party verified EPD or uses an incompatible PCR, it gets auto routed away from award.
Why this is happening now
Hyperscalers are aligning on common disclosure for equipment and materials. The Open Compute Project and the iMasons Climate Accord released an embodied carbon disclosure base specification that standardizes what suppliers must report, with contributions from Google, Meta and Microsoft (OCP+iMasons, 2025). iMasons also published a maturity model that buyers use to request comparable carbon data across materials, equipment and power (iMasons, 2025). At the same time, California made embodied carbon control mandatory for large nonresidential projects with options that depend on EPDs, with wider coverage from January 1, 2026 (California Building Standards Commission, 2025). LEED v5 was ratified in March 2025 and strengthens life cycle carbon as a design and procurement driver (USGBC, 2025).
What hyperscalers actually ask for
Most requests are simple to read and unforgiving to miss. Product specific EPDs that follow EN 15804 or ISO 14025, correct declared unit, and matching PCR to peer products. Plant specific data is preferred when regional GWP limits apply. If the EPD is expired or based on an uncommon PCR, comparability fails and the product cannot be counted toward carbon targets.
The materials that trigger the filter in DC builds
Concrete, reinforcing and structural steel, flat glass, and mineral wool are common hotspots in envelopes and structure. California’s code names these directly and offers a prescriptive EPD based route that many owners mirror in private RFPs (California Building Standards Commission, 2025). On the white space inside the building, the new OCP+iMasons disclosure baseline signals growing scrutiny for MEP and IT equipment where comparable embodied carbon data has been messy until now (OCP+iMasons, 2025).
Proof that demand is real
Big buyers are not waiting on policy. In May 2025 Microsoft announced long term purchases of low carbon cement and Embodied Abatement Credits tied to future concrete for its data centers (Microsoft, 2025). That is a demand signal to suppliers that the EPD is not optional paperwork, it is the key that opens the door.
The market map you are being measured against
Spec writers and owner reps benchmark your EPD against a very large pool, not against a brochure. EC3’s open database now includes well over 150,000 digitized EPDs that teams use to set category baselines and pick lower GWP options (Building Transparency, 2024). In 2025, Building Transparency noted the database was approaching 200,000 EPDs, which grows the comparison set for every bid (Building Transparency, 2025).
Where suppliers get knocked out
Two patterns cause most silent rejections. First, EPD housekeeping: expired declarations, missing A1 to A3 coverage, or a declared unit that does not match the one requested. Second, comparability gaps: using a niche PCR when competitors use a different one, or publishing at product family level when the buyer asked for plant specific. Fixing those is defintely faster than answering a new round of RFIs.
A 60 day plan to clear the filter
- Build the list of SKUs that actually land in data centers and map them to the right PCRs used by your closest competitors.
- Lock a reference year and pull utility, production and waste data for each plant. Do not leave this to “later.”
- Decide the program operator and publication path that fits your market mix. Confirm reviewers’ availability so the schedule is real.
- For concrete and steel, check your EPD GWPs against the regional targets your buyers use. If you do not know them, assume CALGreen style thresholds as a sanity check (California Building Standards Commission, 2025).
- Stage submittals by revenue risk. Products that appear in every hyperscaler campus go first.
What great looks like in your LCA and EPD partner
Look for partners who do the data wrangling rather than hand you spreadsheets to chase. Prioritize a team that is fluent in the PCRs your competitors use, publishes with multiple program operators, and can move from facility EPDs to product specific quickly when buyers ask. Speed matters because EPDs near expiry can torpedo a whole bid window.
The commercial punchline
Embodied carbon rules are now baked into specs and procurement workflows. Federal policy shifts in early 2025 did not change that reality on private campuses and state codes. Treat EPDs as a sales asset that removes a penalty on your product and keeps you in the shortlist. One well timed EPD often protects a mid sized project margin that easily outweighs the document’s cost. The RFP filter is on. Make sure your products pass without drama.
Frequently Asked Questions
What is the single fastest way to keep our data center bids from being filtered out for embodied carbon reasons?
Audit your current EPDs for expiry, declared unit, and PCR alignment with competitors, then publish plant specific updates for the SKUs that show up most often in data center scopes. This prevents comparability failures that auto reject submittals.
Which standards should our EPDs reference to be accepted across markets including hyperscalers?
Most owners expect ISO 14025 and EN 15804 compliant EPDs. Match the PCR used by peer products so the declared unit and system boundaries are comparable. When in doubt, review how products are benchmarked in EC3 and recent award submittals.
Do we need whole building LCA to win, or just EPDs?
Owners typically run WBLCA at the project level. Your job is to supply product specific, plant specific EPDs so your materials can be counted toward reductions. Without comparable EPDs, owners must use conservative defaults that penalize your product.
Will the shift in US federal policy in 2025 reduce embodied carbon requirements for private data centers?
No. Hyperscalers are maintaining or tightening embodied carbon expectations and California’s CALGreen requirements remain in effect for large projects. Private procurement standards and state codes continue to drive market behavior.
About the Author
Eric works at the intersection of sustainability, regulation, and business strategy, helping manufacturers navigate the evolving landscape of EPDs and LCAs. Having spoken with hundreds of teams across North America, brings a deep understanding of what drives ROI, what regulators are asking for, and how companies can stay ahead with smart, scalable approaches to environmental reporting.
