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Briefing Note · BN006 · EPDs and embodied carbon

Environmental Product Declarations

Check that each declaration represents the product and the comparison you intend to make.

Audience:
Buyers checking product evidence and manufacturers preparing to commission a declaration.
Status:
Voluntary product declarations; project specifications or customer requirements may require them.

Version 1.3. Published 8 September 2026. Revised and reviewed 9 September 2026. Next review 9 March 2027. 5-minute read.

Executive summary

An Environmental Product Declaration (EPD) is a standardised report of a product's environmental impacts, based on life-cycle assessment and stated rules. It is a third-party-verified Type III declaration under ISO 14025. Buyers need evidence matching the product, factory coverage, quantity and project method. Manufacturers need reliable production records and a clear specialist brief. Agree the required function and scope before comparing figures: an EPD supplies evidence for an assessment, but does not certify low carbon or technical suitability, or represent a building's whole footprint. [1, 3]

Start here

Check the exact product and declaration, then agree what function and project stages the comparison must cover.

In plain terms

An EPD reports environmental impacts for a stated product and scope, including more than carbon. Check whether it covers the item that will be supplied and installed. Comparable figures need compatible rules, quantities, functions and project assumptions. [1, 3]

Quick evidence check

CheckWhat to record
ProductProduct and stock code, manufacturer, factory coverage; individual product or average.
Rules and validityStandard edition, Product Category Rules (PCR), registration, issue and expiry; registry status.
BasisDeclared or functional unit, quantity conversion, service life and geography.
ScopeLifecycle modules, scenarios, global-warming indicator, biogenic carbon and Module D.
AccountabilityProgramme operator (manages rules and registration), verifier (checks the declaration) and exact source link.

Compare like with like

A declared unit is an amount, such as one tonne. A functional unit also describes the service provided. Compare equivalent function over a common study period, allowing for different service lives and replacements. A1-A3 covers production, excluding delivery, installation, maintenance and disposal. [3]

EN 15804 provides common construction-product rules. Its +A1 and +A2 amendments use different indicators and requirements. Do not mix incompatible results. Keep Module D, potential effects beyond the boundary, separate. Check the assessment method before combining datasets. [2, 3]

Recommended actions

A practical way to start, with suggested owners and timing:

  1. Define the purpose

    Keep the specification, required modules, standard and acceptance criteria for the project.

    Buyer and assessor, before requesting evidence

  2. Build the register

    Link stock items to exact EPD versions, sources, coverage and expiry; keep the declaration and registry check.

    Procurement or merchant data lead, before purchase

  3. Check equivalence

    Confirm performance with the designer and assessor. Record quantities, conversions, losses, service lives, replacements and excluded stages.

    Designer and assessor, before comparison

  4. Agree what to use when an EPD is missing

    Record the assessor-approved generic data or substitute, why it is suitable, its limitations and the plan for better evidence.

    Assessor and buyer, when evidence is missing

  5. Prepare production data

    Agree the specialist scope and programme; keep volumes, energy, materials, waste, allocation records and ownership.

    Manufacturer, before commissioning an EPD

Example in practice

Illustrative comparison: A reports 100 kgCO2e per tonne; B reports 80 kgCO2e per cubic metre. Here kgCO2e means kilograms of carbon dioxide equivalent. B cannot be ranked lower from those numbers. Establish quantities for equivalent performance, then check modules and assumptions. These figures are illustrative, not product data.

Common mistakes

  • An EPD treated as a green certificate: assess the evidence and technical suitability.
  • Average or other-factory data treated as the installed product: verify coverage.
  • An expired or superseded file used without review: check the registry and assessor acceptance.

How Reinventives can help

Our product and supplier data review can deliver a product-evidence register, targeted supplier requests and a gap list. For manufacturers, we can organise the production-data process and specialist handovers. Formal life-cycle assessment, EPD production and verification require appropriately qualified practitioners, programme operators and verifiers.

construction@reinventives.co.uk · 01908 023399

Sources and review dates

  1. 1.EPD International, What is an Environmental Product Declaration? Programme-owner guidance.
  2. 2.EPD International, PCR 2019:14 Construction products, version 2.0.1, 5 June 2025.
  3. 3.BRE Global, PN514 to EN 15804+A2, revision 3.1, 30 November 2023; sections 5.2-5.3.

Product Category Rules: The International EPD System lists PCR 2019:14 version 2.0.1; BRE PN514 revision 3.1 is another programme's rule set. Check the exact rules named in each declaration and the operator's current requirements. [2, 3]

Source scope: programme-owner guidance and BRE rules were reviewed; the full BS EN 15804 standard was not accessed.

Sources accessed and correct as of 9 September 2026.

Next scheduled review 9 March 2027.

Review when programme rules, standards, products, factories, specifications or declaration validity change.

This briefing is general information, not legal, procurement, engineering or assurance advice. Check requirements for the specific organisation, project and contract.

Discuss this requirement

Bring your question on EPDs and embodied carbon, the deadline you are working to and the data you already hold. We’ll discuss the scope, inputs and next step.

Scope, deliverables, timing and fee are agreed in writing before work starts.