What's Missing from Most EPDs and Why It Matters
Environmental Product Declarations (EPDs) have become foundational documents for sustainable construction. They provide verified, transparent data about the environmental impacts of building products, enabling architects, specifiers, and procurement professionals to make more informed choices. With construction products accounting for over 86% of EPDs issued through the International EPD System in 2025, these declarations are clearly central to how the building industry approaches environmental transparency.
However, the value of an EPD depends not only on its existence but also on its completeness. ISO 14025 establishes minimum content requirements for Type III environmental declarations, and these requirements exist for good reason. When information is missing, the usefulness of an EPD for decision-making and comparison is diminished. Understanding what is often absent from published EPDs helps practitioners interpret these documents more effectively and encourages improvement across the industry.
What Should an EPD Contain?
ISO 14025 specifies the minimum content that a Type III environmental declaration must include, designed to ensure that EPDs provide sufficient information for informed interpretation and, where appropriate, comparison between products. The mandatory elements include identification and description of the organization, a clear product description, PCR identification, dates of publication and expiration, life cycle assessment results organized by information modules, content declarations including materials and substances, information on which life cycle stages are included or excluded, and a statement that EPDs from different program operators may not be comparable.
Beyond these basics, ISO 14025 also requires transparency about methodological choices that affect results, including cut-off rules and allocation procedures. Information about data quality, such as whether generic or specific data sources were used and which LCA database supported the assessment, is also expected. These requirements are not arbitrary. Each element serves a purpose in helping users understand the scope, methods, and limitations of the environmental data presented.
The Completeness Gap
Research examining large samples of published EPDs has consistently found that many declarations do not include all mandatory elements. While the majority of EPDs contain core information such as product descriptions and environmental impact results, other required elements are frequently absent. This pattern appears across different program operators and product categories, suggesting it reflects systemic challenges rather than isolated oversights.
Among the most frequently absent elements are cut-off rules and allocation procedures. Cut-off rules specify which minor inputs or outputs were excluded from the LCA due to their negligible contribution to overall impacts, while allocation procedures describe how environmental burdens were distributed when a production process yields multiple products. Both of these methodological choices can significantly affect LCA results, and without knowing what was excluded or how shared impacts were allocated, users cannot fully assess the basis for the reported environmental data.
Clear identification of the declaring organization and detailed product descriptions are also inconsistently provided across programs. Some EPDs offer comprehensive company information while others provide minimal detail, and the level of specificity about product specifications, performance characteristics, and application contexts varies considerably. Similarly, the specific version of the PCR used to develop an EPD is not always clearly documented, which matters because rules evolve over time and EPDs based on different PCR versions may not be directly comparable.
Data quality information presents another common gap. EPDs should indicate whether specific (primary) or generic (secondary) data was used for different life cycle modules and should identify the LCA database that supported the assessment. In practice, many EPDs report that both specific and generic data were used but do not specify which processes relied on which type of data, making it difficult for users to assess data quality or understand the basis for reported results.
Why Does This Happen?
The completeness gap in published EPDs likely reflects several contributing factors rather than a single cause. Product Category Rules must accommodate diverse products within broad categories, which sometimes leads to flexibility in reporting requirements where what is mandatory versus optional may not always be clearly distinguished. Third-party verification focuses on confirming that the underlying LCA was conducted appropriately and that results are accurately reported, but may not always catch missing administrative or contextual information that falls outside the core LCA review.
Different program operators use different templates and formats for EPDs, and some templates may prompt for all required information while others may be less comprehensive. The structure and prompts provided to EPD developers influence what ends up in the final document. Additionally, developing a complete, high-quality EPD requires time, expertise, and attention to detail, and organizations with limited experience or resources may focus on core requirements while inadvertently omitting elements that seem less central to the environmental data itself.
Implications for Practitioners
When reviewing an EPD, it is worth checking whether key methodological information is present. If cut-off rules, allocation procedures, or data quality information is missing, interpret the results with appropriate caution. The absence of this information does not mean the EPD is unreliable, but it does limit your ability to fully understand the basis for reported impacts. Completeness also directly affects comparability, since elements that are not reported cannot be compared and methodological alignment cannot be verified if methods are not disclosed.
If you are in a position to request or specify EPDs through procurement or project requirements, consider asking for complete declarations that include all ISO 14025 mandatory elements. Clear expectations from specifiers can encourage more thorough EPD preparation. For those developing EPDs, a complete declaration is more useful and credible than one with gaps. Working with templates or checklists that prompt for all required elements can help ensure nothing is overlooked, and engaging practitioners with LCA expertise can help ensure that methodological choices are appropriate, well-documented, and clearly communicated in the final declaration.
The Path Forward
The completeness gap in EPDs represents a solvable challenge. Awareness of the issue is growing, standards continue to evolve, and program operators are working to improve consistency and quality across their declarations. Initiatives like ECO Platform in Europe are promoting harmonization and quality assurance across program operators, and the increasing adoption of digital EPD formats, with over 250 digital-format EPDs issued in 2025 alone, may also support more consistent and complete declarations through structured data requirements.
EPDs are valuable tools for environmental transparency in construction, and their growing adoption reflects genuine commitment across the industry to understanding and reducing environmental impacts. Recognizing the current completeness gap is not a criticism of the system but rather an acknowledgment of where improvement is possible. For users, awareness of commonly missing elements supports more informed interpretation of EPD data. For developers, attention to completeness enhances the credibility and usefulness of declarations. Together, these efforts strengthen the foundation that EPDs provide for sustainable decision-making.
Need Support?
Whether you are developing an EPD for your products or trying to interpret environmental data for a project, professional guidance can help navigate the complexities involved. Our team offers life cycle assessment services to support comprehensive EPD development and sustainability reporting services to help organizations communicate their environmental performance clearly and completely.
The EPD Comparability Challenge: What Practitioners Need to Know
Environmental Product Declarations (EPDs) have become essential tools for sustainable construction, helping professionals understand the environmental performance of building products across their life cycle. With over 18,000 valid EPDs now registered in the International EPD System alone, these documents play an increasingly important role in green building certification and sustainable procurement decisions.
One of the key promises of EPDs is comparability. Because they follow standardized methodologies and undergo third-party verification, EPDs should theoretically enable meaningful comparisons between similar products. However, achieving this comparability in practice involves more nuance than many practitioners realize.
The Framework for Comparability
The EPD system is built on a solid foundation designed to support comparison. Product Category Rules (PCRs) establish consistent scope, system boundaries, and methodological requirements for products within the same category. These rules guide the life cycle assessment (LCA) that forms the basis of every EPD. ISO 14025 provides overarching guidance, stating that EPDs developed under the same rules can be compared.
This framework has driven significant progress in environmental transparency across the construction industry. At the same time, research examining EPDs within the same product categories has revealed practical challenges that users should understand when attempting comparisons.
Understanding the Challenges
Functional and Declared Units
The functional or declared unit defines the basis for measurement in an EPD, and identical units are necessary for direct comparison. PCRs often provide flexibility in how these units can be defined, which serves an important purpose since products vary in their functions and applications.
For example, insulation products might be declared per square meter at a specific thermal resistance, per kilogram, or per cubic meter with various performance specifications. This flexibility accommodates the diversity of products on the market, but it means that many EPDs within the same category are not immediately comparable on their stated units.
Some EPDs address this by including conversion factors, which is a helpful practice. However, approaches to these conversions are not fully standardized, so users should exercise judgment when applying them.
Methodological Transparency
Meaningful comparison requires transparency about key methodological choices, particularly cut-off rules and allocation procedures. Cut-off rules determine which minor inputs are excluded from the assessment, while allocation procedures determine how environmental impacts are distributed across co-products. Both can significantly influence results.
When this information is clearly documented, users can assess whether two EPDs are methodologically aligned. When it is absent, comparison becomes more difficult. Research on EPD databases suggests that this information is not consistently reported across all EPDs, which represents an opportunity for improvement in how declarations are prepared and verified.
PCR Version Considerations
PCRs are periodically updated to incorporate improvements and align with evolving standards such as EN 15804, which is a positive aspect of the system's continuous development. However, EPDs developed under different PCR versions may reflect different methodological requirements, potentially affecting comparability.
For practitioners, this means it is worth checking which PCR version was used when comparing EPDs in the same product category. This information is typically included in the declaration, though its prominence varies.
Cross-Program Considerations
EPDs from different program operators may have different document structures and reporting conventions, even when they follow the same underlying standards. Analysis of EPD documents has shown that formatting and organization tend to be consistent within individual program operators but can vary between them.
This is not necessarily a flaw in the system, as different programs serve different markets and stakeholder needs. Platforms like ECO Platform are working to improve harmonization across European program operators. However, cross-program comparisons may still require additional attention to ensure that equivalent information is being assessed.
What This Means for Practitioners
For Specifiers and Designers
EPDs remain valuable tools for understanding the environmental profile of products, even when direct comparison is challenging. When comparing products, it is worth verifying that the EPDs use compatible functional units, are based on the same or equivalent PCR versions, and include the methodological information needed to assess alignment.
Rather than viewing EPDs solely as ranking tools, consider using them to identify environmental hotspots, understand which life cycle stages contribute most to impacts, and engage manufacturers in conversations about improvement opportunities.
For Procurement
As green building requirements increasingly reference EPDs, procurement specifications can help improve comparability by requesting EPDs based on the same PCR and requiring complete methodological disclosure. This does not guarantee perfect comparability, but it creates better conditions for meaningful assessment.
For Manufacturers
Completeness and transparency in EPD preparation support the broader goal of enabling informed decisions. Ensuring that your EPD includes all required methodological information, clearly states the PCR version, and considers the inclusion of conversion factors where relevant can enhance its usefulness to specifiers and improve confidence in the data.
The Path Forward
The EPD ecosystem continues to mature, with ongoing efforts to improve harmonization through mutual recognition agreements, centralized platforms, and standards development. The growth of EPD adoption globally, with strong international development and regional expansion into new markets, reflects the industry's commitment to environmental transparency.
In the meantime, understanding the current state of EPD comparability helps practitioners use these documents more effectively. EPDs provide valuable, verified environmental information that supports better decision-making in construction. By approaching comparisons thoughtfully and verifying methodological alignment, users can maximize the value of this information while recognizing its practical limitations.
The goal is not to diminish the importance of EPDs but to ensure they are used in ways that reflect their strengths. With appropriate attention to the factors discussed above, EPDs can meaningfully contribute to more sustainable building practices.
Need Support?
Navigating EPD development and interpretation can be complex. Whether you are a manufacturer preparing your first EPD or a specifier trying to make sense of environmental data, professional guidance can help. Our team offers life cycle assessment services to support EPD development and sustainability reporting services to help organizations communicate their environmental performance effectively.
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