The EPD Era: How Environmental Product Declarations Are Redefining EU Compliance

Environmental Product Declarations (EPDs) are becoming the backbone of sustainability compliance in the European Union.  As regulations such as the  Ecodesign for Sustainable Products Regulation, the Corporate Sustainability Reporting Directive, and the Construction Products Regulation become stricter, EPDs provide transparent, standardised data on a product’s environmental footprint throughout its life cycle. 

Key Regulatory Drivers

1. Ecodesign for Sustainable Products Regulation (ESPR)
   • Effective: 18 July 2024
   • Scope: Uses EPDs as foundational data for upcoming Digital Product Passports (DPPs), progressively mandatory across key product categories — textiles, batteries, electronics —through to 2030
2. Corporate Sustainability Reporting Directive (CSRD)
   • Includes expanded disclosure requirements around environmental impacts and lifecycle performance
   • EPD data provides reliable input for disclosures under the CSRD
3. Construction Products Regulation (CPR)
   • Enforcement: Expected from 2026, with mandatory Digital Product Passport integration
   • Requirements: Manufacturers must disclose third-party-verified Global Warming Potential (GWP) data via EN 15804-compliant EPDs. By 2030, full lifecycle impact reporting (e.g., acidification, eutrophication) becomes mandatory
   • Outcome: EPDs become essential for public procurement and CE marking compliance

Supply Chain Impact: Tier-by-Tier Insights

1. Upstream (Raw Materials & Components)
   • Manufacturers must compile climate and resource-use data for incoming materials
   • EPDs support decision-making between suppliers and feed into LCA-based digital reporting
2. Manufacturing
   • The integration of Product Category Rules (PCRs) ensures accurate, comparable assessments
   • Detailed EPD data enhances internal optimization for resource efficiency and regulatory compliance
3. Logistics & Transport
   • Though cradle-to-gate EPDs typically exclude logistics, upcoming regulation updates are expanding the scope to include packaging and distribution impacts
4. Downstream (Building Integration & End-of-Life)
   • EPDs facilitate carbon accounting under EPBD
   • They support circular strategies through transparency around recyclability and end-of-life considerations

Strategic Benefits for EU Businesses

1. Regulatory Compliance:
   • EPDs are essential for product approval under CPR, building reporting under EPBD, and marketplace readiness via ESPR and CSRD
2. Procurement Advantage:
   • Public tenders increasingly require EPD data.  Absence of EPDs may cost up to 14% of market share, as seen in the Netherlands
3. Market Transparency:
   • Trusted, verified environmental data enhances competitiveness and fosters buyer trust across sectors

Future Outlook

1. Digital Product Passport Alignment:
   • EPD data will be automatically absorbed into DPPs, making early adoption wise
2. Harmonized Standards:
   • All major EPD programs in Europe operate on EN 15804 guidelines, ensuring cross-sector comparability and consistency
3. Broader Sustainability Integration:
   • As EU legislation tightens around biodiversity, circularity, and resource use, the role of EPDs is likely to expand further

EPDs are evolving from voluntary green credentials into indispensable regulatory instruments within the EU. By embracing EPD creation now, product manufacturers and supply chain operators can not only comply with upcoming regulations but also gain early entry to procurement opportunities, improved transparency, and stronger market positioning in a sustainability-driven economy.

SGS' full suite of services can support the creation and verification of Environmental Product Declarations. Our expert advisory and verification services ensure accurate environmental footprint calculations, while our training programs enhance understanding of EPD concepts and related software.

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