Why Data Centers Make EPDs Nonoptional
Hyperscale builds are exploding, and their net‑zero promises now sit on your loading dock. Owners want proof of low embodied carbon for every megaproject component, from switchgear pads to roof insulation. That proof is an Environmental Product Declaration. If your competitors can hand over verified EPDs faster, they win the slot in the spec and you wait outside. The surge in AI data centers only accelerates this shift (IEA, 2025).
The build boom meets carbon math
Global data center electricity demand is projected to more than double by 2030, with investment swelling to roughly half a trillion dollars in 2024 alone (IEA, 2025) (IEA, 2025). In the United States, data centers are a primary driver of record power demand in 2025 and 2026, according to EIA outlooks summarized by major newswires (Reuters, 2025). Bigger pipelines mean bigger submittal stacks.
Net‑zero targets cascade into your spec sheet
Tech owners have public net‑zero or carbon‑free energy goals by 2030 to 2040, and they track Scope 3. Google’s 2030 net‑zero and 24/7 carbon‑free energy ambition explicitly covers value‑chain impacts (Google, 2025) (Google, 2025). Scope 3 Category 1 requires cradle‑to‑gate emissions for purchased goods and services, which is exactly what an EPD reports for A1 to A3 stages (GHG Protocol, 2025).
Ratings turn promises into submittals
LEED still awards points for product‑specific, third‑party verified EPDs under the MR Building Product Disclosure and Optimization credit (USGBC, 2025). LEED v5, ratified in 2025, moves further toward decarbonization and elevates embodied‑carbon accounting, making product‑level transparency more valuable on tech campuses (USGBC, 2025). BREEAM projects recognize product‑specific EPDs and can award credits for using them, a common path for European data center programs (BRE, 2025).
Policy pressure did not disappear
Several IRA‑linked grants and Buy Clean pilots were pared back or canceled in 2025, reducing some federal pull for low‑carbon materials (Reuters, 2025) (AP, 2025). Yet state and owner requirements continue to bite. California’s Buy Clean program requires facility‑specific EPDs and enforces updated 2025 GWP limits for steel, rebar, glass, and mineral wool (DGS, 2025) (DGS, 2025). University systems and agencies reference those same rules in their capital projects (Caltrans, 2025).
Hyperscalers are asking suppliers for EPDs
The iMasons Climate Accord, whose governing body includes AWS, Digital Realty, Google, Meta, Microsoft, and Schneider Electric, publicly urged vendors to publish ISO 14025, EN 15804 EPDs and make them accessible in common databases to support embodied‑carbon procurement (iMasons, 2024). That open letter mirrors what many bid packages now require: a product “nutrition label” that can be audited.
What this means for manufacturers serving data centers
If your product falls anywhere near structure, enclosure, site concrete, MEP anchorage, cable management, roof assemblies, or interior fit‑out, assume an EPD will be requested. The first submission wins precious time with the owner’s carbon team. Translation for sales: projects with EPD‑ready SKUs tend to move faster through sustainability review and avoid penalty factors that otherwise push specifiers toward competitors.
Fastest route to an EPD that holds up under review
- Choose the PCR your buyers expect, typically EN 15804 for construction materials, validated by a respected program operator.
- Prioritize product‑specific, facility‑specific data. Industry averages rarely satisfy modern procurement for critical packages.
- Align the functional unit and declared modules with how your product is purchased, then proof the math against the owner’s calculator. Small mismatches can stall approvals.
- If the line is new, ask about a prospective EPD. You can refine it when a full production year of data is available.
Avoid the common blockers
Expired documents, wrong PCR version, or company‑wide averages get rejected. So do EPDs that do not isolate A1 to A3 when the credit or policy clearly calls for them. We also see teams forget that state programs like California require the EPD to be valid at installation, not just at submittal (DGS, 2025). Dont let a stale date slip you off the shortlist.
ROI in plain sight
Owners and GCs must hit embodied‑carbon budgets, just as they hit power budgets. When your EPD proves a lower GWP and is easy to verify, you remove friction for the carbon accountant and secure a place in the base bid rather than as a risky alternate. Even a single mid‑sized data hall can repay the EPD effort many times over, which is why quick, white‑glove data collection and operator‑agnostic publishing matter in your partner search.
Threading the needle from here
The data center surge, the ratings shift toward embodied carbon, and persistent state‑level Buy Clean rules converge on one simple requirement. Be EPD‑ready. The manufacturers who package accurate, current, and easy‑to‑use declarations will keep showing up in specs while others watch the crane swing to someone else’s product.
Frequently Asked Questions
Do data center owners actually require EPDs in procurement, or are they just nice-to-have marketing documents?
Many do require them. LEED and BREEAM award credit for product‑specific, third‑party verified EPDs, and top owners pursue those ratings on data center campuses (USGBC, 2025) (BRE, 2025). The iMasons Climate Accord governing body also issued an open letter urging suppliers to publish verified EPDs to support embodied‑carbon procurement (iMasons, 2024).
Which parts of a data center most often trigger EPD requests?
Structure and enclosure materials such as concrete, rebar, steel, deck, roofing, insulation, glass, and aluminum systems are frequent. Site concrete and select MEP supports also appear. These align with credit language that caps structure and enclosure contributions and counts product‑specific EPDs toward thresholds (USGBC, 2025).
Are federal Buy Clean incentives still a driver in 2025?
Federal momentum slowed after several IRA‑related programs were curtailed in 2025, but state rules remain strong. California’s Buy Clean program requires facility‑specific EPDs and enforces updated 2025 GWP limits for designated materials (DGS, 2025).
What standards should our EPD follow for global data center work?
For construction materials, EN 15804 with ISO 14025 Type III verification is the dominant path in Europe and accepted widely elsewhere. Choose the PCR your buyers and program operator expect, and ensure third‑party verification. BRE and other operators outline these norms (BRE, 2025).
How do Scope 3 rules make EPDs more important for tech owners?
Scope 3 Category 1 requires cradle‑to‑gate emissions for purchased goods and services. EPDs provide consistent A1‑A3 data at the product level, which supports owners’ net‑zero targets and regulatory reporting such as CSRD where material (GHG Protocol, 2025) (EFRAG, 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.
