This article explains updates to the rules for creating Environmental Product Declarations (EPDs) specifically for construction products. EPDs are like reports that show the environmental impact of a product throughout its life. In April 2025, EPD International made some big changes to these rules, called Product Category Rules (PCR). This new version is all about making sure the EPDs are clearer, more consistent, and more trustworthy.
What is an EPD?
Basically, an Environmental Product Declaration (EPD) is a standardised report that tells you transparently how your product affects the environmental impact, from raw material extraction until its thrown away. EPDs are based on Life Cycle Assessments (LCAs) and are verified by independent third parties. They are used by businesses to demonstrate environmental performance, comply with regulations, and meet market demands for sustainability.
Six key changes in PCR Version 2.0.0
We have listed six key changes from the recent update. We will delve into each of these changes in more detail in the next chapter. Furthermore, we discuss some implications for businesses and important data to keep in mind.
- Inclusion of capital goods: Infrastructure, such as the construction of power plants, must now be included in the life cycle assessment, especially for production systems utilizing electricity.
- Enhanced data quality requirements: Stricter guidelines on data quality, including clear definitions of primary and secondary data, have been introduced to improve the reliability of EPDs.
- Clarified rules on self-generated electricity: It is now prohibited to "net out" overproduction of self-generated electricity; all generated electricity must be accounted for transparently.
- Default values for end-of-life scenarios: Standardized default values and references for end-of-life stages have been added, similar to the Dutch National Environmental Database (NMD), to ensure consistency.
- Specific rules for multiple products and locations: Detailed guidance has been provided for EPDs covering multiple similar products or production sites, including options for reporting average, representative, or worst-case scenarios.
- Mandatory declaration of data sources: A new requirement mandates the inclusion of a "Declaration of Data Sources" table, specifying the quality and representativeness of data used in each life cycle phase.
Detailed explanation of the changes
1. Inclusion of Capital Goods
Previously, the environmental impacts of infrastructure, like power plant construction, were often excluded from assessments. Now, such capital goods must be included, particularly for processes consuming electricity. This ensures a more comprehensive evaluation of a product's environmental footprint.
2. Enhanced data quality requirements (Section 4.6)
The updated PCR emphasizes the importance of data quality by:
- Differentiating primary and secondary data. Defining primary data as “first hand” data specific to the product and production process. Secondary data is more general , industry-average information and not specific to the product.
- Stricter rules on secondary data: The new rules say that if you're using secondary data, it has to be a really good representation of what actually happens in the manufacturing process. It can't just be any old average. It has to be very close to the real situation.
- Transparency of data sources: Companies now have to be very clear about where their data comes from. They need to say whether they used primary data or secondary data, and where exactly that secondary data came from. This makes the EPDs more believable and trustworthy.
3. Clarified rules on self-generated electricity
Under the new rules, companies cannot offset overproduction of self-generated electricity against consumption ("netting out"). All electricity generated and consumed must be reported separately, providing a clearer picture of energy flows and associated environmental impacts.
4. Default values for end-of-life scenarios
To address variability and uncertainty in end-of-life modeling, the PCR introduces standardised default values and references, akin to those used in the Dutch National Environmental Database (NMD). This facilitates more consistent and comparable EPDs.
5. Specific rules for multiple products and locations
When a company wants to create an Environmental Product Declaration (EPD) for several similar products or production sites, the rules now offer specific ways to do this. Instead of needing a separate EPD for each item, companies can choose from a few methods:
- First, they can use average results. This means they take the environmental impact data from all the products or sites, weigh them by how much of each is produced, and then calculate an average. This gives an overall picture of the environmental footprint of the whole group.
- Second, they can choose a representative product. Here, they pick one product that is typical of the group and use its data for the EPD. This saves time but still provides useful information.
- Third, there’s the option of a worst-case scenario. This means they use the data from the product or site that has the highest environmental impact. While this might seem alarming, it actually provides the most conservative estimate and ensures transparency.
By offering these different options, the new rules provide flexibility for businesses while still making sure that EPDs are transparent and comparable. This helps consumers and other stakeholders understand the environmental impacts of a range of products or operations.
6. A new "Declaration of Data Sources" table is required, detailing:
The new rules now require that every Environmental Product Declaration (EPD) includes a detailed "Declaration of Data Sources" table. This is crucial for ensuring that everyone understands exactly where the information in the EPD comes from. The table must show:
- The origin of the data (primary or secondary): Companies must clearly state whether they used "primary data"—meaning data they collected themselves, specific to their product and processes—or "secondary data," which is general data from outside sources like industry averages or databases. This distinction is vital because primary data is generally considered more accurate and representative.
- Data quality assessments: It's not enough just to list the source; companies also have to assess and describe how good the data is. They must explain how reliable the data is and why it's considered suitable for the EPD. This involves looking at factors like accuracy, age, and how representative the data is of the actual product and its life cycle.
- Representativeness and completeness for each life cycle stage: For each stage of the product's life cycle (from raw material extraction to disposal), companies need to explain how complete and relevant their data is. This ensures that no important environmental impacts are being overlooked and that the data truly reflects the product's journey.
Implications for businesses
The updates to EPD International's Construction PCR Version 2.0 carry significant implications for businesses in the construction sector.
Comprehensive Assessments: Including capital goods and detailed data declarations ensures a more complete environmental profile of products.
Enhanced Credibility: Stricter data quality requirements and transparency measures increase the trustworthiness of EPDs among stakeholders.
Regulatory Compliance: Aligning with updated standards helps businesses meet evolving regulatory and market expectations.
Strategic Planning: Understanding these changes enables better planning for EPD development and sustainability reporting.
How Hedgehog guides you through these changes
Hedgehog offers comprehensive Environmental Product Declaration (EPD) consulting services to help clients transparently communicate the environmental impact of their products while safeguarding sensitive company data.
Our expertise covers providing insights into a product's entire lifecycle environmental impact, including categories such as climate change, water and land use, and toxicity. Hedgehog guides clients through the full EPD process, from executing a Life Cycle Assessment (LCA) to creating an EPD report compliant with ISO 14025, and ensures its inclusion in relevant databases. This service allows for secure sharing of environmental impact data with partners, customers, and stakeholders.
To combat the challenges that the new updates may provide Hedgehog offers solutions.
1. Capital goods: Assessing the capital goods and infrastructure is not required for every company or production line. We will carefully determine if this step is necessary for your EPD.
2. Data quality: Our data experts will guide you through the data collection phase to streamline this process.
3. No Netting Out: Our EPD consultation service clarifies the new rules on self-generated electricity, ensuring that your EPD reflects genuine environmental improvements, not just accounting tricks. We help you demonstrate a true, long-term commitment to sustainability that not only looks good on paper but really benefits future generations.
4. Default values: Data gaps? No problem, we got you covered. Our pragmatic approach ensures the highest quality data collection.
5. Additional rules multiple products: Schedule a call to inventorise how many of your products can be covered by an EPD?
6.Declaration of Data Sources table: This is all taken care of in the data collection support phase.
For more information on our EPD support check our solution page, and have an overview of our pragmatic step by step approach to your sustainability goals.
Or schedule a meeting with one of our experts!
Important Dates
- April 7, 2025: Publication of PCR 2019:14 Version 2.0.0.
- June 20, 2025: Expiration of previous PCR version 1.3.4; all EPDs must comply with Version 2.0.0 thereafter.environdec.com
Businesses are encouraged to review and update their EPDs and related processes promptly to align with the new PCR requirements.
