2. Why Your Business Needs an EPD

Manufacturers don’t create Environmental Product Declarations for philosophical reasons. They respond to concrete market pressures: regulations that mandate environmental data, customers who require it for procurement, and competitive dynamics where verified transparency creates advantage. Understanding whether your business needs an EPD depends on your markets, your customers, and your timeline.

The question isn’t whether EPDs are conceptually good. The question is whether the specific benefits justify the specific costs in your context. For some manufacturers, EPDs are mandatory for market access. For others, they’re strategic differentiators. For some, they’re premature investments that make sense later.

The Regulatory Driver: When You Have No Choice#

Regulations increasingly reference EPDs explicitly, transforming them from optional transparency tools into mandatory compliance requirements.

The EU Construction Products Regulation, which entered force in January 2025, mandates environmental information for construction products. By 2026, manufacturers must declare Global Warming Potential for regulated product categories. By 2030, full EN 15804 compliant EPDs become necessary for many construction materials.

This isn’t guidance or best practice. This is regulatory requirement. If you manufacture construction products for European markets in regulated categories, EPDs become mandatory within defined timelines. Self-declared carbon data or uncertified LCA studies won’t satisfy the requirement.

Public procurement policies increasingly specify ISO 14025 compliant declarations. Government buyers in multiple countries require EPDs for certain product categories. If your business depends on public sector sales, procurement requirements may force EPD development regardless of your preferences.

Some markets move faster than others. The Netherlands, France, and Germany lead European implementation. Nordic countries established EPD requirements years ago. If you sell construction products in these markets, you’re already encountering EPD requirements in tenders and specifications.

The regulatory trajectory is clear. Environmental declarations are moving from voluntary best practice to mandatory disclosure. If regulations apply to your products and markets, the question isn’t whether to get an EPD but when and how.

Green Building Certification: The Market Access Requirement#

LEED, BREEAM, DGNB, and similar green building certification schemes create powerful EPD demand. These schemes award points for using products with environmental declarations. Projects pursuing certification need materials with proper EPDs.

This creates a market access dynamic. Architects and specifiers working on certified projects need to hit point targets. Using products without EPDs means missing points. When they can choose between equivalent products where one has an EPD and one doesn’t, the choice is obvious.

For building product manufacturers, this transforms EPDs from nice-to-have transparency into competitive necessity. Your product might perform better technically and cost less, but if a competing product has an EPD and yours doesn’t, you risk losing specifications on certified projects.

The certified building market is substantial and growing. In major cities, certified buildings increasingly dominate commercial construction. Residential certification expands steadily. If your products go into buildings and you want access to this market segment, EPDs become essential.

Different certification schemes have different EPD requirements. LEED accepts EPDs from recognised programme operators following ISO 14025. BREEAM similarly requires credible declarations. Schemes specify which programme operators they recognise and what standards EPDs must follow.

This means understanding which certification schemes matter in your markets and what EPD requirements they impose. Creating an EPD that doesn’t meet relevant scheme requirements wastes resources without delivering market access.

Customer Requirements: Following the Supply Chain Upstream#

Large corporations increasingly demand environmental data from suppliers. If you supply products to manufacturers, contractors, or retailers with sustainability commitments, EPD requests may arrive in procurement questionnaires or supplier requirements.

Corporate sustainability reporting under frameworks like CDP, TCFD, or upcoming regulations requires companies to measure and disclose supply chain impacts. Your customers can’t report their Scope 3 emissions without data from suppliers. EPDs provide that data in standardised, credible format.

This creates cascading demand. A major retailer commits to net zero across their supply chain. They require suppliers to provide product environmental data. Those suppliers need EPDs to respond credibly. Companies mid-supply chain face pressure from both customers demanding data and their own need to collect upstream information.

Automotive manufacturers, electronics companies, furniture producers, and other sectors with environmental commitments increasingly specify EPD requirements in supplier agreements. If a significant customer requires an EPD, you have strong business case regardless of other factors.

The alternative to providing EPDs might be losing business. When procurement decisions weigh environmental performance and multiple suppliers compete, the one with verified data has advantage. Self-declared claims lack credibility. Marketing materials don’t satisfy corporate reporting requirements. EPDs do.

Competitive Differentiation: When Your Story Needs Proof#

Some manufacturers pursue EPDs proactively for competitive advantage. If your product has genuinely lower environmental impact than competitors, an EPD provides credible proof.

Marketing claims about sustainability face scepticism. Everyone claims their product is greener, more efficient, more sustainable. Claims are cheap. Verification costs money and reveals truth. An EPD backed by independent verification signals serious commitment.

This works when you have actual environmental advantages to document. If your manufacturing process uses renewable energy, if your product contains high recycled content, if your supply chain is optimised for low emissions, an EPD quantifies these advantages credibly.

The differentiation strategy fails if your EPD reveals you’re no better than competitors or worse. EPDs are transparency tools, not marketing tools. They report what the data shows. If the data doesn’t support your environmental story, an EPD highlights weaknesses rather than strengths.

Before pursuing EPDs for competitive positioning, conduct preliminary LCA to understand your actual performance. If results are favourable, EPD verification adds credibility. If results are unfavourable, improvement programmes make more sense than premature transparency.

Risk Management: Avoiding Competitive Disadvantage#

Even without immediate requirements, some businesses pursue EPDs to avoid falling behind. If competitors develop EPDs and you don’t, you risk becoming the supplier without environmental transparency.

Markets move quickly. What’s optional best practice today becomes expected standard tomorrow and mandatory requirement next year. Waiting until EPDs become urgent means compressed timelines, higher costs from rushed development, and potential business loss during development periods.

Early EPD adoption provides time to learn the process, refine data collection, and prepare for tightening requirements. The first EPD takes longer and costs more than subsequent updates. Getting through that learning curve before regulatory deadlines hit reduces pressure.

This forward-looking approach suits manufacturers with long product development cycles or complex supply chains. If creating an EPD would require significant supply chain engagement to collect data, starting early makes sense. Waiting until customers demand EPDs tomorrow leaves insufficient time to engage suppliers, collect data, and complete verification.

Risk management also applies to investor and stakeholder expectations. Companies with sustainability commitments or ESG reporting requirements may need EPDs to demonstrate environmental performance credibly to investors, boards, or sustainability rating agencies.

Sector-Specific Drivers#

Different sectors face different EPD pressures with different timelines.

Construction products face the strongest immediate pressure from EU regulations and green building schemes. If you make insulation, concrete, steel sections, windows, or other building materials, EPDs are becoming mandatory faster than most sectors. The EN 15804 framework provides clear methodology but also means meeting specific European requirements.

Furniture and furnishings for commercial buildings encounter EPD requirements through LEED and other certification schemes. Corporate procurement increasingly specifies environmental declarations. The sector has established PCRs and verification processes but pressure is less immediate than construction.

Electronics and appliances face growing pressure from corporate reporting requirements and upcoming regulations. Complex supply chains make EPDs challenging but large manufacturers increasingly demand declarations from component suppliers. The sector is moving toward EPD adoption but timelines are less defined than construction.

Packaging sees EPD requirements from brand owners seeking to document environmental performance of products and packaging together. Food and beverage companies particularly drive packaging EPD demand. The Extended Producer Responsibility regulations accelerate pressure.

Industrial products face sector-specific dynamics. If you supply into construction (pumps, controls, lighting), you inherit construction EPD requirements. If you supply other manufacturing sectors, requirements depend on customer sustainability programmes.

Understanding where your sector sits in the EPD adoption curve helps gauge urgency. Leading sectors have established programme operators, clear PCRs, and competitive pressure. Emerging sectors have less infrastructure but may face rapid acceleration.

When You Don’t Need an EPD (Yet)#

EPDs aren’t universal requirements. Some situations don’t justify the investment.

If you sell exclusively to markets without EPD requirements or green building schemes, immediate pressure may be absent. Residential construction in certain regions faces less demand than commercial construction. Consumer products outside furniture have limited EPD requirements currently.

If your business is small with limited resources, the cost of EPD development might outweigh benefits if regulatory requirements don’t apply and customers aren’t requesting declarations. Better to invest in improving environmental performance than documenting mediocre performance.

If your product is genuinely minor in building or supply chain environmental impact, customers may not request EPDs. A small specialised component used in tiny quantities might never face EPD requirements even if the overall system needs declarations.

If you’re about to substantially change product design, manufacturing process, or supply chain, creating an EPD for the current version wastes resources. EPDs must be updated when products change significantly. Wait until the new version is established.

If your sector has no established PCRs, creating an EPD becomes more complex and expensive. You might need to develop a PCR first. For innovative or unique products without comparable categories, the infrastructure might not exist yet.

Making the Decision: A Framework#

Evaluate EPD necessity through four questions:

Do regulations require it? Check current and upcoming requirements in your markets. If mandated, timeline and compliance approach become the focus. No decision needed about whether, only about how and when.

Do customers require or request it? Review procurement specifications, customer sustainability requirements, and tender documents. If significant customers specify EPDs, business case is clear. If nobody mentions it, requirement may be distant.

Do competitors have EPDs? Check competitor websites and EPD registries for similar products. If most competitors have declarations, you risk disadvantage without one. If few have them, sector is early in adoption.

What’s your timeline? If regulatory deadlines are five years away, you have time to prepare data systems and supply chain engagement. If customers are requesting EPDs now, urgency increases. If competitors just published declarations, you’re playing catch-up.

These questions create a priority matrix. High regulatory pressure plus customer requirements equals immediate priority. No regulations, no customer requests, and no competitor EPDs suggests watching and waiting. The combinations indicate where EPD development sits in business priorities.

Starting the Process#

If analysis indicates you need an EPD, understanding the complete process helps you plan realistically. You’ll need to assess data requirements, understand costs and timelines, choose a programme operator, and prepare for verification.

The fundamental requirement is adequate data. EPDs require detailed information about materials, energy, transport, and waste across your supply chain. If you don’t have this data collection infrastructure, building it takes time. Some businesses discover that preparing for an EPD drives improvements in data systems that benefit operations beyond environmental reporting.

The Strategic View#

EPDs are tools, not ends in themselves. The goal is market access, regulatory compliance, competitive positioning, or customer requirements. The EPD is how you demonstrate environmental performance credibly in a standardised format.

For some businesses, EPDs are essential short-term priorities driven by clear requirements. For others, they’re medium-term preparations for inevitable market evolution. For some, they remain distant concerns better addressed after establishing data infrastructure and improving performance.

The businesses most disadvantaged are those caught by surprise when requirements arrive suddenly. Whether you need an EPD today or not, understanding where your sector is heading lets you prepare appropriately rather than scrambling reactively.

If your business sells into construction, particularly in Europe, EPD timelines are compressed and requirements clear. If you’re in other sectors, watching regulatory evolution and customer requirements helps you anticipate when EPDs shift from optional to necessary. Either way, the trend toward verified environmental transparency is clear. EPDs are the mechanism that trend operates through.