EN 15804 +A2: Your New EPD Rulebook
Feeling whiplash from the constant upgrades to Environmental Product Declarations? EN 15804 +A2 rewires the core rules for every construction-product EPD published in Europe. Miss a clause and your declaration may land in the reject pile—or worse, the spec that should have been yours ends up with a faster rival. Below is the condensed playbook for staying compliant while keeping sales momentum.
Why this amendment matters right now
July 2022 became the hard cutoff: any new construction-product EPD published in the EU must follow EN 15804 +A2 (IGBC, 2024). Skip it and program operators will not issue a declaration, full stop. The revised EU Construction Products Regulation signed in 2024 further cements +A2 as the baseline for the upcoming digital product passport (EU Regulation 2024/3110, 2024). In short, +A2 is no longer a choice but the passport control for market access.
From seven indicators to nineteen
The old A1 version asked for seven core impact categories. A2 demands 13 core indicators plus six additional categories—19 data points in total (Ecomatters, 2024). That new breadth covers acidification, particulate matter, land-use change, and more. Carbon still leads the pack, but it now shares the stage with a bigger cast that specifiers increasingly scrutinize.
Carbon split into four buckets
Global Warming Potential is no longer a single headline number. +A2 requires separate reporting for fossil CO₂, biogenic CO₂, land-use change CO₂, and a combined total. Think of it as switching from a single “calories” figure to a detailed nutrition label. The split exposes hidden trade-offs—biogenic storage upfront, biogenic release at end-of-life—so early data discipline saves embarrassing corrections later.
End-of-life and Module D are now mandatory
A2 closes the optional-module loophole. Every construction-product EPD must declare modules C1–C4 and Module D, even if recycling routes are only theoretical today (Ecomatters, 2024). Manufacturers that control or at least document take-back scenarios can turn this from burden to branding by showing tangible circular benefits.
Digital data or bust: the ILCD requirement
Program operators now want the background datasets in ILCD format. The spec sounds nerdy, yet it underpins machine-readable EPDs and the EU digital passport. If your LCA workflows still run on spreadsheets, factor in extra time for data conversion or team up with a provider that outputs ILCD files automatically (IGBC, 2024).
Commercial upside hidden in the fine print
Yes, +A2 looks like extra paperwork, but it unlocks larger tenders. Public buyers in Germany, the Nordics, and the Netherlands already flag +A2 compliance in pre-qualification screens. Private developers chasing taxonomy-aligned finance follow the same path. Treat the extra impact categories as talking points that differentiate your product when bids cluster around similar carbon scores.
How to keep speed while staying sane
- Start data hunts with the new indicator list so you never back-fill reports later.
- Model transport and end-of-life early. Assumptions drive Module D credits that often tip comparisons.
- Insist on ILCD-ready output from any LCA consultant or software. Re-formatting after verification burns weeks.
- Align stakeholder reviews around the four GWP splits to avoid last-minute “where did the carbon go” emails.
Key takeaways
EN 15804 +A2 is here to stay and getting woven into EU product passports. It widens the environmental lens, locks in full life-cycle coverage, and demands digital-ready datasets. Treat compliance as a sprint now and your specifications pipeline will thank you later.
Frequently Asked Questions
Do I have to revise an existing EN 15804 +A1 EPD before its five-year expiry?
No. A1 EPDs stay valid until their listed expiration date. Publish any new or renewed EPDs under +A2 to keep market access (IGBC, 2024).
How many impact categories must appear on the EPD cover page?
The EPD must report 13 core indicators. Six additional categories can sit in the annex or background report, yet many buyers still request the full set (Ecomatters, 2024).
Is ILCD data submission public?
ILCD is a file format specification. Operators need the file to verify calculations, but you are not obliged to make proprietary data public (EU Regulation 2024/3110, 2024).
Will US or ISO 21930 EPDs satisfy EU buyers post-A2?
Not automatically. A2 is not fully harmonised with ISO 21930. Exporters aiming at EU tenders need an A2-compliant version or an addendum that maps indicators one-to-one.
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.
