Is Your Product Data‑Center Ready? The New Baseline
Hyperscale owners are tightening embodied‑carbon rules while state policies and rating systems turn EPDs from nice‑to‑have to bid‑critical. If your mix, panel, or rack support ships without a current, plant‑level EPD and a clear path under common GWP limits, you are invisible to data‑center specifiers. Use this checklist to confirm you can clear procurement gates fast, with fewer email chases and zero last‑minute scrambles.
What “data‑center ready” means in 2025
Data‑center buyers now ask for product‑specific, facility‑specific Type III EPDs that report A1–A3 GWP and follow ISO 14025 and EN 15804. Many projects also expect shipping distance and A4 disclosure when thresholds include transport, as in Colorado policies (OSA, 2025). EPDs must be current within five years and third‑party verified.
Private and public owners are converging on concrete, steel, glass, and insulation as priority materials. California and Colorado already set numeric GWP ceilings that teams check against your EPD the moment you submit it (DGS, 2025; OSA, 2025).
The quick baseline specifiers use
Here is the pattern we see on data‑center bid docs and owner playbooks.
- A plant‑level EPD, not industry‑average, aligned to the relevant PCR and still inside its validity window. Some owners explicitly reject industry‑wide declarations for compliance checks (UCOP BCCA guidance, 2025).
- A GWP number that is at or below the active state or owner limit for your category. Examples include hot‑rolled structural steel at 1,010 kg CO₂e per tonne and rebar at 755 kg CO₂e per tonne in California, effective January 1, 2025 (DGS, 2025).
- Digital submittal readiness. Caltrans and Washington are standing up databases that expect clean, machine‑readable EPDs and project metadata, which speeds reviews and audits (Caltrans, 2025; Washington Commerce, 2024).
Hyperscalers are raising the floor
Major cloud builders publicly target lower‑carbon concrete and steel, with pilots and specs that push reductions of 20 to 50 percent from regional baselines. Microsoft reports Scope 3 growth driven by rapid build‑out and is moving to low‑carbon materials, even mass‑timber hybrids for some campuses (Microsoft ESR, 2024; Microsoft Cloud Blog, 2024). Meta has integrated low‑carbon concrete into latest designs and continues to pilot deeper reductions (Meta Sustainability, 2024). AWS documents use of lower‑carbon steel and concrete across dozens of sites (About Amazon, 2024).
Takeaway for suppliers: transparent EPDs are the entry ticket, and convincing reductions against credible baselines keep you in the short‑list.
Policy tailwinds that matter, even as federal incentives shift
State Buy Clean programs anchor the market by requiring EPDs and setting ceilings. California’s 2025 limits cover structural steel, rebar, flat glass, and mineral wool, while Caltrans added asphalt, concrete, and CMU EPD submittals for bids opened from February 1, 2025 (Caltrans, 2025). Colorado’s Office of the State Architect updated 2025 concrete strength‑class limits and includes A4 when specified (OSA, 2025).
LEED v5 increases emphasis on embodied‑carbon outcomes, which keeps product transparency central for teams pursuing credits on large technical campuses (USGBC, 2025). The U.S. EPA’s draft label program will recognize low‑embodied‑carbon products using EPD data, creating one more registry where buyers will look first (EPA, 2024).
The seven‑point supplier checklist
Use this to self‑audit before you meet a data‑center GC or owner.
- EPD type and scope: Product‑specific, facility‑specific, Type III. Conforms to ISO 14025, ISO 14040/44, and EN 15804. Declared unit matches how your product is bought and installed.
- Validity and PCR fit: Publication date within five years, underlying PCR current or clearly identified for next renewal. Replacement PCR mapped for your next update.
- GWP proof against a target: Your A1–A3 GWP at or under the owner or state ceiling for your category, with a clear regional comparison table ready. Note when A4 is included for compliance.
- Submittal hygiene: Machine‑readable PDF, mix or grade IDs, plant address, electricity source, and contact info visible. Provide batch or heat numbers if requested. Caltrans and other portals reject incomplete data (Caltrans, 2025).
- Portfolio coverage: One EPD per producing plant or mix family. Multi‑plant companies should map each facility to its served markets to avoid penalties for “wrong region” assumptions.
- Reduction narrative: Short memo that explains drivers behind your GWP number, such as SCM percentages, EAF share, or recycled content. Owners increasingly ask suppliers to document the why, not just the what (Open Compute Project, 2024).
- Update rhythm: Calendarized refresh plan so your document never ages out mid‑project. Flag planned mix tweaks or new furnaces early so design teams can hold your spec.
Common trip‑wires that stall data‑center bids
Two patterns tank otherwise good offers. First, EPDs that declare only industry averages or omit the producing plant. Reviewers cannot verify compliance and will move on. Second, mismatched declared units. If your sheet steel EPD is by square meter and the spec is by tonne, provide a clean conversion note and keep the density reference handy. Small friction losses add up to weeks.
Where the bar is set today
Concrete: Many teams target 15 to 50 percent lower GWP than local baselines for structural elements, with strength‑class caps written into specs. Colorado publishes category‑specific numbers suppliers can benchmark against (OSA, 2025).
Steel: California caps unfabricated hot‑rolled sections at 1,010 kg CO₂e per tonne and rebar at 755 kg CO₂e per tonne for state work. Private owners often mirror or tighten those values in their internal guides (DGS, 2025).
Glass and insulation: Flat glass limits and mineral wool ceilings are active in California, and we see growing requests to pair EPDs with recycled‑content declarations for QA checks (DGS, 2025).
Sell the ROI, not just the document
A current, defensible EPD prevents penalty assumptions that push your product out of contention and can shorten procurement cycles. On multi‑hundred‑million dollar campuses, one retained spec can offset the cost of producing the EPD many times over. Reliable cost averages are hard to pin down because each project scope differs, yet owners consistently prefer ready‑to‑submit transparency over enviornmental guesswork.
Your next move
Pick a recent reference year, lock plant‑level utility and material data, and map your product to the dominant PCR used by competitors. Publish a product‑specific, facility‑specific EPD and prepare a one‑page compliance brief against California and Colorado limits. Keep a simple refresh plan. When the RFP hits, you will not just be data‑center ready, you will be first‑call ready.
Frequently Asked Questions
Do data center owners really look for plant-level (facility-specific) EPDs?
Yes. University of California guidance under California’s Buy Clean policy requires facility-specific EPDs for covered materials, and state and private owners increasingly mirror that standard for verification (UCOP BCCA, 2025).
Which categories most often carry numeric embodied-carbon limits on data center projects?
Does LEED still care about product EPDs for data centers?
Yes. LEED v4.1 already rewards product EPDs in MR credits, and LEED v5 strengthens focus on embodied carbon, keeping EPDs useful for tech campuses that pursue certification (USGBC, 2025).
Are federal incentives dependable in late 2025?
Federal programs have been in flux. Do not rely on them for baseline eligibility. State Buy Clean rules, private owner specs, and agency portals like Caltrans’ EPD system are the steadier drivers of demand in 2025 (Caltrans, 2025).
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.
