The EPD Explosion: Hyperscalers Set the Pace
Hyperscalers build at a scale that bends markets. Their data center pipelines and Scope 3 goals are pushing materials with Environmental Product Declarations from nice-to-have to table stakes. If you make concrete, steel, glass, flooring, cabling, or enclosures, this wave is already at your door.
Why hyperscalers move markets
When the largest cloud providers tweak a spec, entire supply chains retool. Their projects run continuously across regions and repeat designs, so a procurement rule that rewards products with third‑party verified EPDs gets multiplied hundreds of times. EC3’s open database grew to nearly 200,000 digitized EPDs by mid‑2025, up from about 100,000 in early 2024, a signal that disclosure has escaped the pilot phase (Building Transparency, 2025).
Datacenters just changed the math
Electricity demand tied to data centers and AI is surging, which translates into more shells, slabs, racks, and cables. The IEA estimates data centre electricity could roughly double by 2030, with AI accelerators as a major driver, and identifies data centers as a key contributor to recent demand revisions (IEA, 2025) (IEA Energy and AI, 2025). That scale compresses adoption cycles for product‑specific EPDs, because owners want auditable embodied‑carbon baselines before the concrete trucks roll.
Private demand is now a policy signal
Hyperscalers are not waiting for federal carrots. AWS reports dozens of data centers built with lower‑carbon concrete and steel and highlights supplier work to generate mix‑level EPDs that pinpoint carbon hotspots for reductions (Amazon Sustainability, 2024). This creates a repeatable template for RFPs that require verifiable disclosures instead of marketing claims.
Public rules narrow the field
States are codifying what private owners already ask for. New York requires EPDs for all concrete mixes on state projects beginning January 1, 2025, and uses EPD‑reported GWP to set and ratchet limits over time (NYS OGS Buy Clean Concrete Guidelines, 2025). Colorado’s Buy Clean policy defines acceptable, product‑specific Type III EPDs and ties compliance to maximum GWP thresholds for eligible materials (Colorado OSA Buy Clean Colorado Act Policy, 2024). California’s Buy Clean program requires facility‑specific, third‑party verified EPDs for covered materials and rejects industry‑average declarations (California DGS, 2024). If your catalog lacks current EPDs, you are screened out before price gets a hearing.
EPDs are the common language procurement trusts
An EPD is not a trophy, it is a data sheet built on ISO standards and a PCR that defines the rules. LEED’s Building Product Disclosure and Optimization credit specifically rewards projects that use EPD‑backed products, because disclosures enable apples‑to‑apples comparisons within a category (USGBC, 2024). That is why buyers prefer them. EPDs lower risk, support faster internal reviews, and reduce the back‑and‑forth on substitutions when carbon caps apply.
Why procurement teams love this shift
Procurement wants clean, comparable, defensible data. EPDs give a third‑party verified GWP, a clear scope, and a validity window that aligns to project schedules. They plug into EC3 for quick benchmarking and into owner portals for audit trails. Most importantly, they make it easier to award on value instead of just unit cost when hitting embodied‑carbon targets would otherwise trigger penalties or redesigns.
What manufacturers can do next
Start with a portfolio triage. Prioritize the SKUs most likely to appear in hyperscale builds, then map existing declarations against expiries and target markets. If a PCR decision is unclear, look at competitors’ declarations and the program operators common in those bids. Choose a publishing path that your buyers recognize, for example SmartEPD in the United States or IBU in Europe, while staying operator‑agnostic so you can meet regional preferences.
Data collection will make or break your timeline
Most delays happen inside the factory fence. Lock the reference year, list all inputs, and pre‑clear metering and waste data before anyone calculates. A great LCA partner will not dump spreadsheets on your team. They will run white‑glove collection across plants, resolve meter anomalies, and surface early reduction options such as switching to Type IL cement, recycled content adjustments, or logistics tweaks that reduce A4. It sounds basic, but this is where speed, ease, quality and completeness are won.
ROI, without the hand‑waving
Reliable averages for EPD costs vary by product and scope, and posting a universal number would be misleading. What we do see consistently is that one mid‑sized hyperscale or public project win often dwarfs the cost of a declaration when an EPD avoids a carbon penalty or a last‑minute swap. If your EPDs are current, bids move faster and fewer specs slip through your fingers. That feels very real on quarter close, it is definately noticeable.
Your fast path to spec‑ready
Keep three habits. Track state Buy Clean thresholds and expiries quarterly. Maintain a live EPD register that flags products within one year of renewal. Standardize PCR choices per category so new SKUs can inherit a credible rulebook. With those in place, your team can say yes when the hyperscaler or agency RFP lands, and you will be competing on performance, not scrambling for paperwork.
References used in this article: (IEA, 2025) (IEA Energy and AI, 2025), (NYS OGS Buy Clean Concrete Guidelines, 2025) (NYS OGS, 2025), (Colorado OSA Buy Clean Colorado Act Policy, 2024) (OSA, 2024), (California DGS, 2024), (USGBC, 2024), (Building Transparency, 2025), (Amazon Sustainability, 2024).
Frequently Asked Questions
Do hyperscalers explicitly require EPDs in their construction RFPs or just prefer them?
Public owner guidance varies, but state Buy Clean policies like New York’s and Colorado’s explicitly require product‑specific EPDs for covered materials. Hyperscalers often mirror these rules in procurement, and several have published case studies and standards that depend on mix‑level EPD data to drive embodied‑carbon cuts (NYS OGS, 2025; OSA, 2024; Amazon Sustainability, 2024).
Will older EPDs hurt my chances of getting specified for data centers?
Any valid EPD typically satisfies owner requirements within its validity window. Age matters mainly when an EPD is within months of expiry or if a contract references limits or PCR updates that your document does not meet. Keep a renewal calendar and avoid expiring during construction.
Which program operator should we publish with to reach hyperscalers?
Choose an operator recognized in the project geography and by your buyers. In the U.S., SmartEPD is common, while IBU is frequent in Europe. Most owners care that the EPD is Type III, third‑party verified, and aligned with an applicable PCR, not the specific logo.
Do we need new PCRs for novel products going into data centers?
Usually not. Most categories map to existing PCRs, and a good LCA partner can recommend the dominant PCR in your competitive set. New PCR development takes time and is more typical for large portfolios.
About the Author
With a passion for sustainability and a love for complex data, Toby helps manufacturers efficiently collect data from across their organization and get their EPDs done right. He’s especially interested in how AI can support human expertise, helping R&D and factory teams work faster, smarter, and with less friction.
