Circularity Indicators in EPDs: How Recycled Content and End-of-Life Data Are Reshaping Declarations

Introduction: Beyond Carbon — The Circularity Dimension of EPDs

Environmental Product Declarations have traditionally focused on environmental impacts — greenhouse gas emissions, ozone depletion, acidification, eutrophication. These impact indicators answer the question: what damage does this product cause to the environment? But as the EU’s circular economy agenda matures, a new set of questions is gaining prominence: what resources does this product consume, what waste does it generate, and what happens to it at end of life?

The answer lies in the circularity-related indicators already present in EN 15804+A2 EPDs — and increasingly demanded by building-level assessment frameworks, green procurement criteria, and the forthcoming Digital Product Passport. This article explores the circularity indicators in EPDs, how they are calculated, what they mean for product comparisons, and why they are becoming strategically important for construction-product manufacturers.

Circularity Indicators in EN 15804+A2

Resource Use Indicators

EN 15804+A2 requires every EPD to report a set of resource use indicators that quantify the inputs consumed across the product’s life cycle:

From a circularity perspective, the most relevant indicators are SM (Secondary Material) — which directly quantifies recycled content — and the PERM/PENRM split, which reveals how much embodied energy is stored in the product as material rather than consumed as process energy.

Waste and Output Flow Indicators

EN 15804+A2 also requires reporting of waste categories and output flows that describe what happens to the product’s material at end of life:

Module D: Beyond the System Boundary

Perhaps the most strategically important circularity indicator in an EPD is Module D — benefits and loads beyond the system boundary. Module D quantifies the net environmental benefit (or burden) of reusing, recycling, or recovering energy from the product at end of life, expressed as avoided impacts compared to primary production.

The methodology for Module D follows the „avoided burden” approach: the environmental benefit of recycling is calculated by comparing the impact of producing secondary material from the recycled feedstock against the impact of producing equivalent primary material from virgin resources. The net difference — positive or negative — is reported in Module D as an informational module outside the system boundary.

For products with high recycling potential — such as steel, aluminium, and copper — Module D can show significant net environmental benefits, reflecting the avoided emissions from displacing primary material production. This makes Module D a powerful tool for demonstrating the circular economy value of recyclable construction products.

Why Circularity Indicators Are Gaining Strategic Importance

EU Circular Economy Action Plan and ESPR

The EU Circular Economy Action Plan and the Ecodesign for Sustainable Products Regulation (ESPR) are driving a regulatory shift toward circularity requirements for products placed on the EU market. While construction products are primarily regulated under the CPR, the overarching circular economy framework influences how construction product performance is assessed.

The CPR 2024/3110 itself includes provisions for material composition and recyclability data in the Digital Product Passport — data that draws directly on the circularity indicators already reported in EPDs.

Green Building Certification Systems

Major green building certification systems are increasingly incorporating circularity metrics alongside traditional carbon and energy criteria:

EU Taxonomy Circular Economy Objective

The EU Taxonomy includes transition to a circular economy as one of its six environmental objectives. Technical screening criteria for the circular economy objective reference material efficiency, recycled content, and end-of-life recyclability — all of which can be evidenced through EPD circularity indicators.

Green Public Procurement

EU GPP criteria for construction products increasingly include circularity requirements — minimum recycled content thresholds, recyclability requirements, and design-for-disassembly criteria. EPD circularity indicators provide the verified data needed to demonstrate compliance with these procurement requirements.

How to Improve Your Product’s Circularity Profile

Input Side: Recycled Content (SM)

Increasing the secondary material (SM) input — the recycled content — is the most direct way to improve the input-side circularity of your product. Strategies include:

• Post-consumer recycled content: Using recovered materials from demolished buildings or consumer waste streams. Example: recycled aggregate in concrete, recycled steel scrap in EAF steelmaking.
• Pre-consumer recycled content: Using manufacturing by-products and process waste as inputs. Example: fly ash and ground granulated blast furnace slag (GGBS) as supplementary cementitious materials.
• Industrial symbiosis: Using waste or by-products from other industries as inputs. Example: gypsum from flue gas desulphurisation in plasterboard manufacturing.

Output Side: End-of-Life Recovery (MFR, CRU)

Improving the end-of-life circularity profile requires designing products and systems that facilitate material recovery:

• Design for disassembly: Using mechanical fasteners instead of adhesives, modular construction, reversible connections.
• Material identification: Clear labelling of material types to facilitate sorting and recycling at end of life.
• Mono-material design: Minimising composite materials that are difficult to separate and recycle.
• Avoiding substances of concern: Eliminating materials that contaminate recycling streams (e.g., heavy metals, persistent organic pollutants).

Module D: Quantifying the Benefit

To demonstrate strong Module D benefits in your EPD, ensure that your LCA includes realistic end-of-life scenarios based on actual recycling rates and recovery efficiencies for your product in your target markets. Conservative end-of-life assumptions understate the circular economy benefit; overly optimistic assumptions undermine credibility.

Circularity Indicators and the Digital Product Passport

The forthcoming Digital Product Passport (DPP) under CPR 2024/3110 is expected to include material composition and circularity data. While the specific DPP data requirements will be defined in implementing acts (not yet published), the circularity indicators already present in EN 15804+A2 EPDs provide a ready-made data source.

Manufacturers who already report SM, MFR, CRU, and Module D values in their EPDs will have the circularity data infrastructure in place when DPP requirements crystallise. This is another reason why investing in comprehensive EPD programmes now delivers long-term strategic value beyond immediate certification and procurement needs.

The Bottom Line

Circularity is no longer a niche sustainability narrative — it is becoming a regulated product characteristic, a procurement criterion, and a competitive differentiator. EN 15804+A2 EPDs already contain the circularity indicators that regulators, specifiers, and building certification systems are asking for: recycled content, end-of-life recovery rates, and Module D net benefits.

Construction-product manufacturers who understand and optimise these indicators are positioning themselves for a market where circularity performance sits alongside carbon performance as a key factor in material selection. The data is already in the EPD. The strategic advantage lies in knowing how to use it.

Information current as of publication date. Circularity requirements in building regulations and certification systems are evolving. Check specific programme requirements for current criteria.