EPDs are critical but watch out for scams

With the increasing focus on quantifying carbon and climate impacts as we move to a zero carbon future, the ‘language’ of carbon data transmission has become increasingly important to the extent that this sector has registered its first scams. The most common documents to communicate the Life Cycle Analysis’ (LCA) derived carbon and other environmental data about products, buildings and infrastructure projects are known as EPDs or ‘Type III Environmental Declarations’.

EPDs are a third party verified, scientific, comparable, and internationally recognised report; that contains comprehensive information that disclose data relating to the environmental impacts of the product's entire life cycle using LCA. In short they are a summary LCA report.

EPDs are not ecolabels, they do not evaluate the conformity of the products or compare the pros and cons of the products, but helps governments, companies, industry experts (most specifically LCA practitioners), procurement officer, architects, designers, builders and end users etc. to better understand the comprehensive environmental impact of products and whether they are sustainable.

EPDs are an environmental LCA data reporting format issued in compliance with Standards issued by the International Organization for Standardization or ‘ISO’ under the 14025 or 21930 Standards depending on product categories and an ‘EN’ norm, 15804 issued by European Union. All of these are used globally including in the EU, UK, United States, Australia, New Zealand, Japan, and many other countries, but increasingly the EN norm is the called up by the majority of rating tools and hence, users.

At the moment, EPD certification has been comprehensively promoted and applied in the field of green buildings. EPDs are the one of two main criteria used by architects to choose green building materials for the LEED V4 green building certification process in the United States (and approximately 170 other countries) and an important reference for green building ratings; EPDs are also one of the main evaluation items of the green building materials selection for other international Green Building standards such as UK’s BREEM, Germany’s DGNB and Green Star as used in Australia and New Zealand. At the same time, EPDs can also help procurement officers to comply with relevant environmental regulations or policies, such as product carbon and water footprint data, impact on acidification, eutrophication of water bodies, depletion of natural resources, and energy consumption etc.

The Green Building Council of Australia (GBCA) new ‘Buildings’ rating tool that is part of their ‘Future Focus’ suite of rating tool adjustments has doubled down on the use of EPDs in its latest tool by expanding the scope and depth of relevance of them as the way to demonstrate progress towards the 40% Carbon Net Zero target by 2030 and 100% Net Zero Carbon by 2050. These targets now include Embodied Carbon Emissions of products as demonstrated by the data delivered by EPDs.

EPDs have gradually developed and are driven by the ever-increasing demand for quantitative environmental information in the global market to the extent that the importance of EPDs in procurement processes globally, has meant that imposters and scam artists have entered the market and have duped some manufacturers into paying for ‘EPD Certificates’ that are just single sheet ‘certificates’ that are bogus and totally meaningless in international procurement processes.

To be clear, an EPD is more than just a ‘certificate’ it is a summary LCA report that includes real data to be used in the LCA models of the projects needing the data. These may come with stand-alone logos or certificates recognising or promoting that a product has an EPD but it must come with the 7-15 page EPD Summary LCA report content required by the ISO or EN standards and sought by the LCA modellers to plug into their ‘whole-of-project’ LCA models usually to show the extend by which mostly climate (but also other) impacts have been mitigated by the products selected and procured by the project.

Without this data no document can be classed as an EPD and GreenTag has now ‘busted’ several of these documents that have been purchased in good faith by their clients but shown to be bogus. At least one Australian manufacturer has been terminated from certification by GreenTag for refusing to stop using an ‘EPD Certificate’ that we showed them was bogus but they refused to stop representing it as an ‘EPD’ on their website. Fortunately, it seems they eventually saw the light, as we note that they now have a EN compliant EPD from a proven local Provider, although they remain uncertified by GreenTag. Unfortunately, just recently we have been provided another ‘EPD Certificate’ by a new client from the same organisation that continues to operate from China.

Another form albeit lesser form of ‘scam’ is perpetrated by actual, sometimes potentially inexperienced, LCA practitioners, who have a copy of some proprietary LCA software, that comes with in-built LCA databases that may or may not have relevant data to the project at hand included. Yet even if the data is not within the database, they undertake ‘estimates’ based on ‘proxy’ data and represent the outcome as a valid EPD, instead of taking the significant amount of time it takes to properly research and calculate accurate life cycle inventory data.

While the process described of using adjusted proxy data is valid LCA technique, the validity of the ‘estimating’ process depends on many factors not the least of which is accuracy and the factual basis on which the data in the database is modified. In a recent proposal GreenTag won, the proposed client obtained a number of quotes, one of which was from a company in Portugal that was 10% of the quote we submitted. Fortunately, we were able to explain to the client where there were gaps in key data they needed and we went on to prepare that EPD that was a mandatory submission to the Qatar World Expo as part of their procurement requirements. The EPD was approved by the International Consultant validating the Carbon Score for the event and the client went on to win that bid for steel supply to one of the main stadia.

So make sure you check the experience and qualifications of any EPD provider and make sure you research what a reasonable cost is for an EPD, as well as what an EPD looks like so you don’t get scammed by an organisation that has adopted a local domain extension of a well-known international EPD association that on checking, confirmed it has no representative in that country.

David Baggs is CEO & Program Director of Global GreenTag International Pty Ltd the international Ecolabel, Modern Slavery Declaration and EPD Program Operator. He is also a multi-award winning green building architect, Life Fellow of the Australian Institute of Architects, and Inaugural co-CEO of EPD Australasia.