An Environmental Product Declaration (EPD) is a Type III environmental declaration under ISO 14025: a standardised, independently verified document that reports the life-cycle environmental performance of a product against pre-set Product Category Rules (PCRs). It is built on a life cycle assessment (LCA) of the product and is multi-category, covering global warming, acidification, eutrophication, ozone depletion and resource use, not a single carbon figure.
What changes in 2026 is not the document but the demand for it. The revised EU Construction Products Regulation (CPR), Regulation (EU) 2024/3110, moves the environmental performance of construction products from a voluntary claim toward a regulated declaration, with EN 15804 named as the calculation basis. For manufacturers exporting into the European Union and to buyers in Singapore, the United Arab Emirates and Saudi Arabia, an EN 15804 EPD is becoming the common proof of declared environmental performance.
Key takeaways
- An EPD is an ISO 14025 Type III declaration built on an LCA, reporting multiple impact categories against a PCR.
- Regulation (EU) 2024/3110 entered into force on 7 January 2025; its environmental requirements apply from 8 January 2026.
- EN 15804:2012+A2:2019 has been the mandatory basis for all new construction-product EPDs since October 2022.
- The workflow is prepare, then independently verify, then publish: three separate parties, not one.
- GreenSutra prepares the LCA and EPD data (steps 1 to 3); an independent competent third party verifies and a programme operator publishes.
What an Environmental Product Declaration is
An Environmental Product Declaration (EPD) is a Type III environmental declaration governed by ISO 14025. It reports the life-cycle environmental performance of a product against Product Category Rules (PCRs) set in advance for that product category. The EPD reports results. It does not set targets and it does not pass or fail a product.
Two properties define it. First, an EPD is multi-category. It reports global warming, acidification, eutrophication, ozone depletion, resource use and further indicators, rather than a single climate number. Second, an EPD is built on a life cycle assessment (LCA) of the product, modelled to ISO 14040 and ISO 14044. A product carbon footprint (PCF), calculated to ISO 14067:2018, is the single climate indicator that sits inside that same LCA. For the full comparison between an LCA, an EPD and a PCF, see the LCA guide.
The PCR is what makes two EPDs comparable. A PCR fixes the functional unit, the system boundary, which life-cycle stages and impact categories to include, and the reporting format. An EPD must be prepared against the PCR for its product category. Where no PCR exists, one is developed through the programme operator before an EPD can be published.
The 2026 driver: the EU Construction Products Regulation (EU) 2024/3110
The main regulatory driver for EPDs in 2026 is the revised EU Construction Products Regulation (CPR), Regulation (EU) 2024/3110. It entered into force on 7 January 2025. Its environmental requirements, including the declaration of a construction product’s environmental performance, apply from 8 January 2026, with enforcement and penalty provisions phasing in from 8 January 2027. The European Commission is to provide the calculation method, based on EN 15804. The regulation also sets the basis for a construction digital product passport.
The exact indicator dates in the phase-in should be confirmed against the published regulation before any filing, as the transitional provisions are detailed. The practical effect is already clear: EU buyers and specifiers increasingly require an EN 15804 EPD as the accepted proof of a product’s declared environmental performance.
| Date | Milestone |
|---|---|
| 7 January 2025 | Regulation (EU) 2024/3110 entered into force. |
| 8 January 2026 | Environmental performance declaration requirements apply. |
| 8 January 2027 | Enforcement and penalty provisions begin to phase in. |
EN 15804:2012+A2:2019 and the A to D module structure
For construction products, the core PCR is EN 15804:2012+A2:2019. The +A2 amendment was approved in July 2019 and has been the mandatory basis for all new construction-product EPDs since October 2022. An EPD prepared to an older version is no longer valid for new declarations under this basis.
EN 15804 organises results into standardised life-cycle modules, so that an EPD from one manufacturer can be read against another. The modules run across the product life cycle, with module D reporting benefits and loads beyond the system boundary.
| Module | Stage | Covers |
|---|---|---|
| A1 to A3 | Product stage | Raw materials, transport, manufacturing. |
| A4 to A5 | Construction stage | Transport to site and installation. |
| B1 to B7 | Use stage | Use, maintenance, repair, operational energy and water. |
| C1 to C4 | End-of-life stage | Deconstruction, transport, waste processing, disposal. |
| D | Beyond the system boundary | Reuse, recovery and recycling potential. |
The prepare, verify, publish workflow
An EN 15804 EPD is produced by three separate parties in sequence. Preparation, verification and publication are distinct roles, and the credibility of the declaration depends on keeping them separate.
- Model the product life cycle as an LCA to ISO 14040 and ISO 14044, using primary and background data.
- Select the applicable PCR, EN 15804 for construction products, and a recognised programme operator.
- Compile the EPD in the programme’s format from the LCA results.
- An independent competent third party verifies the LCA and EPD against the PCR and ISO 14025.
- The programme operator registers and publishes the EPD, with a fixed validity period, commonly up to five years, after which it is renewed.
GreenSutra performs steps 1 to 3, the preparation of the LCA and the EPD data. Step 4 is carried out by an independent competent third party. Step 5 is carried out by the programme operator. Programme operators include the International EPD System (Environdec) and IBU, among others. GreenSutra does not verify, assure, register or issue an EPD.
Why EU, Singapore, UAE and Saudi buyers ask exporters for an EN 15804 EPD
Manufacturers exporting construction products into the European Union, and increasingly exporters of other goods, are asked for a verified EPD as the common evidence of environmental performance in green procurement and building-rating systems. The same request now comes from buyers in Singapore, the United Arab Emirates and Saudi Arabia. An EPD prepared to ISO 14025 and EN 15804 travels across these markets, because it rests on a shared standard rather than a market-specific claim.
One boundary is worth marking. The Carbon Border Adjustment Mechanism (CBAM) is not satisfied by an EPD. CBAM importers report embedded emissions under a dedicated EU method, separate from the EPD route.
For an exporter based in India, the work ahead of 8 January 2026 is the preparation: a defensible LCA, the correct EN 15804 PCR, and an EPD compiled in a programme operator’s format, ready for independent verification. GreenSutra prepares that evidence and stops there, leaving verification to an independent third party and publication to the programme operator. Preparation begins with the underlying life cycle assessment.
Environmental Product Declarations in 2026, answered
What is an EPD in 2026, in one sentence?
An Environmental Product Declaration is a Type III environmental declaration under ISO 14025, built on a life cycle assessment, that reports a product's multi-category environmental performance against pre-set Product Category Rules, and in 2026 it is increasingly required as procurement proof under EU rules.
When do the environmental requirements of Regulation (EU) 2024/3110 apply?
The revised EU Construction Products Regulation (EU) 2024/3110 entered into force on 7 January 2025. Its environmental requirements apply from 8 January 2026, with enforcement and penalty provisions phasing in from 8 January 2027. The European Commission is to provide the calculation method, based on EN 15804.
Which standard governs construction-product EPDs?
EN 15804:2012+A2:2019 is the core Product Category Rule for construction products. The +A2 amendment was approved in July 2019 and has been the mandatory basis for all new construction-product EPDs since October 2022. It organises results into modules A1 to A3, A4 to A5, B1 to B7, C1 to C4, and module D.
Does GreenSutra verify or issue the EPD?
No. GreenSutra prepares the life cycle assessment and the EPD data, which is steps 1 to 3 of the workflow. An independent competent third party verifies the LCA and EPD against the PCR and ISO 14025, and the programme operator registers and publishes it.
Preparing an EN 15804 EPD for export? The starting point is a defensible study, not the declaration itself. GreenSutra prepares the underlying life cycle assessment and the EPD data for independent verification, and the LCA guide sets out how the LCA, the EPD and the product carbon footprint relate.
Primary sources
- Regulation (EU) 2024/3110 (Construction Products Regulation), EUR-Lex
- EN 15804:2012+A2:2019, Sustainability of construction works, Environmental product declarations
- ISO 14025:2006, Environmental labels and declarations, Type III environmental declarations
- European Commission, Construction Products Regulation overview