Do I need plant‑specific EPDs if my product ships from multiple factories?

Procurement teams increasingly compare like for like at the plant level. Where energy mixes and transport differ, plant‑specific or at least plant‑weighted EPDs reduce the risk of overstated GWP on scorecards (IBU, 2024–2025; Colorado OSA, 2025).

Will an older EPD within its validity window still work for bids?

Yes, valid EPDs typically qualify, but expiries during a bid window can trigger compliance issues and last‑minute substitutions. Keep 6–12 months of runway on high‑volume SKUs to avoid surprises (Caltrans, 2025).

Is EN 15804+A2 mandatory for my next EPD?

For European programs like IBU, A2 has been mandatory since the A1 transition ended in October 2022. Many buyers now expect A2‑aligned indicators even outside Europe, so check the RFP and the intended operator before you start scoping (IBU, 2024–2025).

Do EPDs still matter if federal incentives change?

Yes. State policies, owner requirements, and LEED v5 ratification continue to drive embodied‑carbon documentation on real projects, independent of federal shifts (USGBC, 2025; Colorado OSA, 2025).

How fast can we stand up credible EPD coverage?

Speed depends on data readiness and partner capacity. Teams that centralize utility data, log production and waste cleanly, and use a white‑glove partner for collection and verification can move far faster than the industry norm without sacrificing quality.

Supplier Scorecards Are Getting Brutal

What “brutal” looks like on real RFPs now

Public owners and large GCs are asking for EPDs by default, not exception. Caltrans requires EPD submittals for hot mix asphalt and concrete on projects with bid openings starting February 1, 2025, plus Buy Clean California materials like steel and flat glass (Caltrans, 2025) (Caltrans, 2025). Colorado sets maximum GWP limits for multiple materials and requires product‑specific, Type III EPDs for state projects begun in 2024, with updates posted in January 2025 (Colorado OSA, 2025).

LEED v5 was ratified March 28, 2025 and elevates embodied‑carbon assessment and reduction, so specifiers are standardizing on verifiable product data instead of marketing claims (USGBC, 2025) (USGBC, 2025).

The new minimum for product data

Program operators in Europe no longer accept A1‑era EPDs for construction products; EN 15804+A2 is the baseline and has been since the A2 transition ended in October 2022 at IBU, with updated PCR Part A in April 2024 (IBU, 2024–2025). That means more indicators, clearer end‑of‑life rules, and stricter documentation. In North America, state Buy Clean policies and owner criteria typically require product‑specific, third‑party verified Type III EPDs aligned with the relevant PCR, not industry averages (Colorado OSA, 2025).

Why buyer scorecards suddenly bite

CDP Supply Chain members now push disclosure across tens of thousands of suppliers, and many translate those responses into procurement scorecards that prefer low‑carbon, well‑documented products (CDP, 2025) (CDP, 2025). At the same time, the EU’s Ecodesign for Sustainable Products Regulation will phase in Digital Product Passports, making environmental data portable and inspectable across borders starting with priority categories like steel and aluminum (European Commission, 2024).

Five signals you are drifting off the spec list

Your top‑volume SKUs lack product‑specific EPDs or the EPDs expire within 6–12 months.
EPDs cite old A1 methods instead of EN 15804+A2, or they omit required indicators.
Plant‑specific differences are masked by a single corporate average, so bidders see inflated GWPs for some sites.
Submittals fail basic checks, like missing verifier info, outdated PCR, or mis‑scoped modules.
RFPs mention LEED v5 and ask for embodied‑carbon documentation you cannot instantly provide (USGBC, 2025).

A revenue‑first playbook you can start this quarter

Map commercial exposure by SKU, plant, and market. Prioritize EPDs where specification volume and margin are highest. Select PCRs that match your competitive set and target operator, since comparability matters in head‑to‑head bids. For the US, many teams publish with a digital‑friendly operator and for Europe they often use IBU, but being operator‑agnostic keeps options open later (IBU, 2025). Lock a renewal calendar so nothing lapses during bid season.

Make data collection painless so it actually happens

Winning teams remove friction. Ask for a partner that handles white‑glove data capture from utilities and production, schedules the internal interviews, and keeps plant managers out of spreadsheet hell. Expect ruthless project management, fast LCA iteration, and clean handoffs to your chosen program operator. You should spend your time approving assumptions, not hunting invoices.

How to meet scorecards without boiling the ocean

Start with the reference year you can document thoroughly. If a product is new, a prospective EPD can work, then you true‑up after a full year. Aim for product‑ and plant‑specific declarations where the same SKU ships from multiple sites. Use the latest PCR, and check whether owners specify A2 compliance or ISO 21930 alignment by name. Where data is scarce, say so plainly and record the plan to improve at next renewal.

Quick win metrics your sales team can use tomorrow

Percentage of revenue covered by current, product‑specific EPDs.
Share of bids in states or owners with EPD or GWP requirements.
Median GWP position versus category benchmarks where available.
Months of runway before any EPD expiry on top 20 SKUs.

If these numbers are hard to produce, that is your early warning light.

Avoid three traps that quietly kill margin

Chasing a perfect PCR while RFPs pile up, instead of matching what competitors and key owners already use.
Letting A1‑era or nearly expired EPDs sit in submittal folders, then discovering the issue after bid day.
Treating a single multi‑plant average as “good enough,” which can overstate emissions for lower‑carbon sites and lose you tie‑breakers.

What changes next

Public procurement and private owner policies will keep tightening. California and Colorado already embed EPDs and material GWP limits into project delivery, and agencies like Caltrans are expanding EPD coverage to mainstream materials on fixed dates, not “someday” (Caltrans, 2025). In Europe, ESPR and Digital Product Passports will make environmental data a normal part of doing business, not a brochure footnote (European Commission, 2024). The teams that prove performance quickly, consistently, and with minimal lift will win more specs. The rest will definately feel it in their pipeline.

Sources cited in text for verification

Caltrans Environmental Product Declarations page, updated August 2025 (Caltrans, 2025) (Caltrans, 2025).
USGBC LEED v5 support page confirming March 28, 2025 ratification and project guidance (USGBC, 2025) (USGBC, 2025).
CDP Supply Chain disclosure program overview, 2025 cycle statistics (CDP, 2025) (CDP, 2025).
Colorado Office of the State Architect, Buy Clean Colorado Act policy and 2025 GWP limits (Colorado OSA, 2025).
IBU program guidance confirming EN 15804+A2 as the basis and PCR Part A update April 2024 (IBU, 2024–2025).
European Commission communications on the Ecodesign for Sustainable Products Regulation and Digital Product Passports, July 2024 (European Commission, 2024).