Module D: Your EPD’s Second Life Credit
Manufacturers lose bids when they ignore the carbon story after demolition. Module D adds that missing chapter, turning future reuse and recycling potential into hard-number benefits right on the EPD front page. Here is why skipping it can cost you projects—and how smart data prep keeps the calculation painless.
Module D in a nutshell
Think of Modules A to C as a movie that ends at the scrapyard. Module D rolls the credits (pun intended) but then shows a post-credit scene where your product becomes feedstock for something new. The numbers report potential greenhouse-gas savings from avoided virgin production once the product is reused, recycled, or sent to energy recovery (EN 15804 +A2, 2019). Since 2024 most European program operators treat Module D as mandatory; North-American PCR revisions are quickly catching up.
Why specifiers suddenly ask for it
Public tenders in the Netherlands and Denmark now score up to 15 % of the embodied-carbon criteria on Module D performance alone (Rijkswaterstaat, 2024). Major contractors mirror that weighting to stay pre-qualified. Ignore the line item and your cradle-to-gate steel panel looks 25 % dirtier than a rival with identical chemistry but better end-of-life prospects (SteelConstruction.info, 2025).
How the math works
- Quantify material flows leaving the system at end-of-life (kg of scrap, reusable parts, recovered energy).
- Apply quality-correction factors—an 0.8 value for down-cycled crushed concrete is common.
- Multiply by current primary production impacts and subtract the burdens of processing. The result can be positive (a credit) or negative (a load). EN 15804 gives the exact formula; most PCRs echo it.
Reuse beats recycle, recycle beats landfill
A timber beam reused in the same structural grade often earns a 1:1 credit because no re-milling is needed. That same beam chipped into MDF triggers extra energy, slicing the credit by roughly 40 % (ConstructionLCA, 2025). Design for deconstruction early if you want the bigger win later.
Watch the crystal-ball risk
Module D assumes tomorrow’s steel mill looks like today’s. Yet EU policy aims to cut blast-furnace carbon intensity 60 % by 2035. Over-crediting is possible. Some program operators now publish forward-looking factors that shave benefits by 10-15 % to stay realistic (ECO Platform, 2024).
Commercial upside you can quote
• A 2025 UK study found façade systems showing a 12 % lower life-cycle GWP after Module D leaped from third place to first in a £14 M office tender (BCSA, 2025).
• The World Green Building Council projects circular-economy credits like Module D could cut global construction emissions 3 % annually by 2030 (WGBC, 2024).
That is spec-sheet gold when owners chase Science-Based Targets.
Data-collection pitfalls—and the shortcut
The headache is rarely the calculation software, it is tracking scrap rates on the shop floor and realistic recovery scenarios with suppliers. Teams that shove this work onto plant engineers see delays stretch from six weeks to six months. Hand off the wrangling to a partner that interviews your recyclers, validates grid factors, and pre-loads PCR defaults so your R&D leads can stick to, well, R&D.
Quick checklist to nail Module D
- Confirm your PCR demands it; many 2020 versions still called it optional.
- Map end-of-life routes with real processors, not wishful thinking.
- Capture product drawings early; dimensions dictate reusable share.
- Keep scrap tickets as pdf or csv, not jpeg photos—auditors hate those.
- Check for double-counting with recycled-content claims in Module A.
Tying it together without ribbon
Module D flips waste into asset by quantifying future avoidance of virgin materials. Do the homework once, bank credibility on every bid thereafter. Get the data right the first time and your EPD becomes a living résumé for circular design, not a dusty certificate slowly expiring in marketing’s Dropbox. One less thing to worry about tommorow.
Frequently Asked Questions
Is Module D mandatory for my next EPD?
In the EU: yes for most construction products under EN 15804 +A2, which program operators enforced from mid-2024. In the US it depends on your PCR; many updates due in 2025 will require it for steel, concrete, and insulation.
How big can a Module D credit be?
Credits vary by material. Reusable steel sections often earn 0.3–0.5 kg CO₂e per kg of product; crushed masonry might see only 0.05 kg CO₂e because of lower quality factors (BCSA, 2025).
Does a high recycled content in Module A cancel Module D benefits?
Partly. The more secondary material you declare upfront, the smaller the pool left to credit at end-of-life. Transparent allocation rules avoid double counting.
Can I ignore future decarbonization when calculating Module D?
Most guidance still uses today’s emission factors, but some operators now let you apply projected factors if you document the assumption. Check your operator’s technical manual.
What data trips auditors most often?
Missing evidence for recovery rates and quality-correction factors. Keep signed letters or contracts from recyclers; screenshots from websites rarely pass muster.
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
