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.
Originating from Barcelona, Laia’s educational journey led her to pursue secondary studies in the south of France. Her Bachelor’s degree in Economics and International Management allowed her to develop an analytical mindset. During her Master’s in International Business and Management, she engaged in numerous research study cases and actively participated in the creation of different business plans. This helped her develop an ability to critically analyze and address the strategic challenges that companies encounter.
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