Do You Have EPDs? Why They're the Foundation of Your DPP

If you manufacture construction products in Ireland and you have been paying attention to the Digital Product Passport conversation, you have probably heard that DPPs will require environmental data. But what does that actually mean in practice? The answer, for most manufacturers, starts with three letters: EPD.

Environmental Product Declarations are not new. They have been part of the sustainable construction conversation for over a decade. But their role is about to change fundamentally. Under the revised Construction Products Regulation (CPR 2024), EPDs shift from being a voluntary marketing advantage to a core compliance requirement. If you already have EPDs, you are ahead of the curve. If you do not, you need to start now.

What Is an EPD?

An Environmental Product Declaration is a standardised document that quantifies the environmental impact of a product across its lifecycle. Think of it as a nutrition label, but for environmental performance. Instead of calories and fat, an EPD declares global warming potential, ozone depletion, acidification, resource depletion, and waste generation.

EPDs for construction products are governed by EN 15804, the European standard that defines the rules for developing EPDs in the construction sector. EN 15804+A2, the current revision, aligns with the EN 15978 framework for whole-building lifecycle assessment and ensures consistency across product categories.

To produce an EPD, a manufacturer commissions a Life Cycle Assessment (LCA) of their product. This LCA examines raw material extraction, manufacturing, transport, installation, use, and end-of-life. The results are then verified by a third party and published through a programme operator - an organisation accredited to manage and publish EPDs.

Programme Operators Relevant to Irish Manufacturers

Several programme operators are active in the European market. The most relevant for Irish manufacturers include:

EPD Ireland - operated by the Irish Green Building Council (IGBC), this is the home programme for Irish manufacturers. Publishing through EPD Ireland gives you strong visibility in the domestic market and aligns with Irish green building certification schemes.
EPD International (The International EPD System) - based in Sweden, this is one of the largest global programme operators. Many multinational manufacturers use this system.
IBU - the German programme operator, widely used across Central Europe. If you export to Germany or Austria, IBU EPDs carry significant recognition.
INIES - the French database, relevant if you supply the French market where EPDs (known as FDES) are already effectively mandatory for public projects.

Each programme operator has its own Product Category Rules (PCRs) that define the specific methodology for your product type. These PCRs are increasingly harmonised, but differences remain. Choosing the right programme operator depends on your target markets, your product category, and your commercial strategy.

Why EPDs Are Becoming Mandatory

Until recently, EPDs were primarily driven by green building rating systems. LEED, BREEAM, and Home Performance Index (HPI) in Ireland all award credits for products with EPDs. Specifiers working on certified green buildings sought out products with published EPDs, and manufacturers responded to that market pull.

CPR 2024 changes the dynamic entirely. The revised regulation introduces Basic Work Requirement 7 (BWR7) - the sustainable use of natural resources. This is not optional. Under BWR7, construction products will need to declare their environmental performance through structured data within the DPP. The most practical and credible source for that environmental data is the EPD.

In short, EPDs are moving from the “nice to have” column to the “must have” column. This is not a distant future scenario. The implementing acts under CPR 2024 are being drafted now, and manufacturers who wait for final deadlines will find themselves scrambling.

The Specific EPD Data That Feeds Into DPPs

Not every number in an EPD will necessarily appear in the DPP, but the core environmental indicators are central. The key data points include:

Impact Category Indicators

GWP (Global Warming Potential) - measured in kg CO2 equivalent, this is the headline metric. It covers GWP-total as well as the subcategories: GWP-fossil, GWP-biogenic, and GWP-luluc (land use and land use change).
ODP (Ozone Depletion Potential) - measured in kg CFC-11 equivalent.
AP (Acidification Potential) - measured in mol H+ equivalent.
EP (Eutrophication Potential) - freshwater, marine, and terrestrial, each with distinct units.
ADPE and ADPF (Abiotic Depletion Potential) - elements/minerals and fossil fuels respectively.

Resource Use and Waste

Use of renewable and non-renewable primary energy.
Use of secondary materials and recovered energy.
Hazardous and non-hazardous waste disposed.
Radioactive waste.

Lifecycle Stages

EN 15804+A2 divides the lifecycle into modules: A1-A3 (production), A4-A5 (construction), B1-B7 (use), C1-C4 (end of life), and D (benefits beyond the system boundary). DPPs will require data at the module level, not just a single aggregated figure. If your existing EPD only covers cradle-to-gate (A1-A3), you may need to extend coverage.

What If You Do Not Have EPDs Yet?

If you are an Irish construction product manufacturer without EPDs, the message is straightforward: start now. Here is why timing matters.

A typical EPD project takes 3 to 6 months from commission to publication. That timeline includes:

Data collection (4-6 weeks) - gathering energy consumption, raw material inputs, transport distances, waste data, and manufacturing process information. This is often the most time-consuming step, especially if your internal data management is not well organised.
LCA modelling (4-8 weeks) - your LCA consultant models the environmental impacts using specialist software (typically SimaPro or GaBi/Sphera) and the relevant PCR.
Third-party verification (3-6 weeks) - an independent verifier reviews the LCA and EPD. Programme operators maintain lists of approved verifiers.
Publication (2-4 weeks) - the programme operator reviews and publishes the EPD.

If you need to develop Product Category Rules first (because your specific product type does not have an existing PCR), add several more months. This is less common for mainstream construction products but can arise for specialist or innovative products.

Cost considerations: EPD costs vary significantly depending on product complexity, data availability, and whether you are doing individual product EPDs or sector/industry EPDs. For a single product EPD in Ireland, expect to invest somewhere in the range of EUR 8,000 to EUR 20,000, covering LCA consultancy, verification, and programme operator fees. Sector EPDs shared across an industry association can reduce per-manufacturer costs significantly.

What If Your EPDs Are Expiring?

EPDs typically have a validity period of 5 years. If your EPDs were published in 2021 or earlier, they will expire before DPP requirements take effect. When you renew, take the opportunity to:

Update to EN 15804+A2 if your original EPD was under the older +A1 version. The A2 revision changed several impact categories and added new ones. DPPs will almost certainly require A2-compliant data.
Extend lifecycle coverage to include use-stage and end-of-life modules if your original EPD was cradle-to-gate only.
Improve underlying data quality. Five years of additional manufacturing data gives you a stronger, more representative LCA.
Align with emerging DPP data schemas so that the data can be extracted and structured for DPP purposes without rework.

How Programme Operators Are Preparing for DPP Integration

Programme operators are not standing still. They recognise that EPDs need to feed directly into DPPs, and several are developing machine-readable data formats alongside the traditional PDF publications.

EPD International has been developing ILCD+EPD format - a structured XML data format that allows EPD data to be read by software systems, not just humans. The ECO Platform’s ECO Portal aggregates EPDs in digital format across multiple programme operators. These developments directly support DPP integration.

EPD Ireland, through the IGBC, is engaged with European-level discussions on how EPD data will flow into DPPs. Irish manufacturers working with EPD Ireland should stay in contact with the programme about evolving digital data requirements.

Practical Advice for Irish Manufacturers

Here is a clear action plan:

Audit your current EPD status. List every product family. Note which have EPDs, which EPDs are expiring, and which products have no EPD coverage at all.
Prioritise by market exposure. Start with your highest-volume products and those sold into markets where EPDs already carry weight (public procurement, green-certified projects, export markets like France or the Nordics).
Choose your programme operator strategically. EPD Ireland makes sense for domestic market positioning. If you export significantly, consider dual registration or an international programme.
Invest in data infrastructure now. The LCA data collection process reveals gaps in your manufacturing data management. Energy metering, raw material tracking, waste segregation records - improving these systems now pays dividends not only for EPDs but for the broader DPP data requirements.
Think beyond the EPD. Your EPD is one data source for the DPP, but not the only one. Start thinking about how EPD data will sit alongside Declaration of Performance data, substances of concern data, and product identification data in a unified digital format.

EPDs are not just an environmental reporting exercise. They are the foundation of your DPP environmental data, and getting them right now will save significant cost and disruption when DPP deadlines arrive. Start the conversation with an LCA consultant today - your future compliance team will thank you.