One Missing EPD Can Sink A Multi Million Dollar Bid

Why one document decides a seven figure outcome

EPDs are no longer nice to have. New York requires EPDs for all concrete mixes on state projects starting January 1, 2025, with max GWP limits by strength class (NYS OGS, 2025) (NYS OGS, 2025). California sets enforceable GWP ceilings for structural steel, rebar, flat glass, and mineral wool, and it specifies that EPDs must be facility specific and valid at installation to prove compliance (DGS, 2025) (DGS, 2025). When a spec calls for those documents and you do not have them, price becomes irrelevant.

Real world example 1: New York concrete 2025

A ready mix supplier bids competitively on a state building. The owner checks submittals against the Buy Clean Concrete guideline. No EPD means no way to confirm GWP against the published limits, so the supplier is swapped out for a mix with a compliant, third party verified EPD. The rule is explicit that mixes must carry EPDs starting 2025, so the risk of being deemed non compliant is real (NYS OGS, 2025) (NYS OGS, 2025).

What would have prevented it: a rolling EPD plan tied to high volume mixes, plus an expiry calendar to refresh documents before the next bid cycle.

Real world example 2: California structural materials

A steel fabricator wins on price but cannot supply facility specific EPDs that show GWP under the DGS limits for plate and sections. Awarding authorities use these EPDs to confirm compliance. Without them, the bid team faces material substitution, change order costs, or a non responsive determination depending on the solicitation language. DGS also rejects industry average EPDs for compliance checks, so the wrong document type kills the path to award (DGS, 2025) (DGS, 2025).

What would have prevented it: locking the correct PCR and program operator early, then collecting plant level data to generate facility specific EPDs rather than leaning on industry averages.

Real world example 3: State projects that now bake EPDs into the bid set

Colorado’s Office of the State Architect requires EPDs to be specified in bid documents for eligible materials on state projects starting January 1, 2024. Designers must verify that submitted EPD GWPs are at or below the state limits. Show up without one and your product cannot be confirmed as compliant with the spec, which puts the offer at risk during responsiveness checks (Colorado OSA, 2025). Oregon DOT likewise requires EPDs for covered materials on highway and large maintenance projects in its administrative rule 731 005 0910, which flows straight into contract compliance language (ODOT, 2025).

What would have prevented it: coordinating with estimators months before advertisement to confirm that every specified eligible material already has a current, verified EPD aligned with the state rule.

The quiet private sector multiplier

Owners chasing LEED v4.1 often require a basket of product specific EPDs for the MR credit worth up to 2 points. Miss the EPD and your product cannot contribute to the tally, which tilts selection toward a competitor that does contribute (USGBC, 2024) (USGBC, 2024). You might never see this in a loss report, but it absolutely affects selection.

The five traps that sink compliance at the last minute

1. Using an industry average EPD where the buyer demands facility specific. California spells this out clearly for its covered materials (DGS, 2025).
2. Picking the wrong PCR, which forces rework during verification and burns the bid window. A PCR is the rulebook of Monopoly. Ignore it and the game falls apart.
3. Letting EPDs age out within 90 days of bid or delivery. Many specs require validity through installation.
4. Multi plant production without plant specific modeling, which breaks state rules that test each facility’s GWP.
5. Data silos that slow the LCA. Utility bills, scrap, transport, and volumes must be ready for the reference year.

Fast fixes that keep bids alive

Start with a portfolio gap scan. Map top revenue SKUs to projects targeted in the next 6 to 12 months. Prioritize EPDs for products appearing in public specs or in states with Buy Clean rules. Choose a partner that leads ruthless data collection inside your org, not one that emails you templates and waits. Align on operator agnostic publishing so you can meet buyer preferences in the US and EU. If a product is new, consider a prospective EPD to cover early bids, then update after a full year of production.

Timing and document quality matter more than you think

Caltrans now requires EPD submissions for concrete and hot mix asphalt on larger projects, with dollar withholds if EPDs are late. The policy even states EPDs must be valid at the time quantities are submitted, which catches teams that try to slide with expired docs (Caltrans, 2025). That is an expensive lesson to learn on a live job.

Checklist for zero drama submittals

• Confirm product specific, facility specific EPDs where state compliance or the spec demands it.
• Verify PCR, modules, and declared unit match the spec language.
• Track expiries 180, 120, and 60 days out and schedule re verification before they pinch a bid.
• Build a one page proof pack for each product that cites the program operator, PCR, verification status, validity date, and GWP. Hand it to estimators and sales so they can attach it instantly.

The takeaway for commercial teams

We do not win the work we cannot qualify for. In 2025, several states and many owners treat an EPD as eligibility, not marketing. The cheapest number does not matter if the paperwork is missing or misaligned. Get the data in order, pick the right rulebook, and publish on time. This is definately the lowest cost way to protect multi million dollar bids.