What is an EPD and why does it matter for construction procurement?

Environmental Product Declarations (EPDs) are standardised documents that quantify the environmental impact of a product over its life cycle. In construction, they are increasingly required by public procurement regulations across Europe.

An EPD is not a green label. It does not certify that a product is environmentally superior. It certifies that the manufacturer has measured and disclosed their environmental data according to an independently verified methodology.

What an EPD actually contains

A construction product EPD contains quantified environmental data covering stages from raw material extraction (A1) through manufacturing (A2–A3) and — depending on the product category — installation, use, and end-of-life. The core indicator is Global Warming Potential (GWP), measured in kg CO₂ equivalent — what most people mean when they talk about the carbon footprint of a product.

Beyond GWP, EPDs report a standardised set of indicators including ozone depletion potential, acidification potential, eutrophication, and abiotic resource depletion. All values are expressed per declared unit — typically per kilogram, per cubic metre, or per square metre of product.

Why construction procurement is changing

For decades, environmental claims in construction were largely self-declared and unverified. A manufacturer could call a product „sustainable” or „low-carbon” based on any internally defined criteria. EPDs changed that by requiring third-party verification against a common methodology — ISO 14025 and EN 15804.

European procurement policy has moved in the same direction. EU directives increasingly require public contracting authorities to include environmental criteria in tenders. The Level(s) framework, the EU Taxonomy for Sustainable Finance, and national green procurement policies in Germany, the Netherlands, Denmark, and France all reference EPDs explicitly.

The regulatory pressure behind EPD adoption

The EU’s Construction Products Regulation, revised in 2024 as Regulation 2024/3110, will require environmental declarations for many product categories as a condition of CE marking. This is not a voluntary programme — once implementing regulations come into force, EPDs will be mandatory for the relevant product families. Polish manufacturers who obtain EPDs now will have the documentation already in place when these requirements take effect.

The EU Taxonomy for Sustainable Finance defines „substantial contribution” criteria for construction activities that include whole-life cycle carbon assessments. Any building that seeks to qualify as a sustainable investment under the taxonomy needs LCA-backed data on its materials — which means EPDs from its suppliers.

How EPDs differ from other environmental claims

There are three types of environmental declarations under ISO 14020 standards. Type I are ecolabels — pass/fail criteria decided by a third party. Type II are self-declared claims — a manufacturer states something about their product without external verification. Type III are EPDs — quantified data, third-party verified, based on product category rules.

EPDs are the only format that enables meaningful numerical comparison between products. A specifier can look at two concrete mixes, both with EPDs, and compare their GWP values on a consistent basis. That comparison is impossible with ecolabels or self-declared claims, which use different criteria and different methodologies.

What this means for Polish manufacturers

Poland’s construction industry is deeply integrated into European supply chains. Polish concrete producers, steel manufacturers, insulation companies, and window fabricators supply projects across Germany, the Netherlands, Scandinavia, and the Baltics — markets where EPDs are already expected by architects, contractors, and developers.

For these manufacturers, the question is not whether to get an EPD, but when. Waiting until EPDs become legally mandatory means entering an already-crowded market, competing against suppliers who have years of verified environmental data and the commercial credibility that comes with it.