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From EPD to Digital Product Passport: What You Already Have and What You Need

· 10 min read · DPP Delivery
EPD DPP Data Conversion

If your organisation has invested in Environmental Product Declarations, you are better positioned for Digital Product Passport compliance than you might realise. EPDs and DPPs are not the same thing, but they share a significant overlap in data requirements. Understanding what you already have, what you are missing, and how to bridge the gap is the most efficient path to compliance.

This article maps the relationship between EPD data and DPP requirements, identifies the gaps, and outlines a practical conversion process for Irish construction product manufacturers.

Understanding the Relationship

An Environmental Product Declaration is a standardised document presenting the environmental performance of a product based on a Life Cycle Assessment (LCA). In the construction sector, EPDs follow EN 15804, the European standard for sustainability of construction works. They are published through accredited EPD programme operators such as EPD Ireland, IBU (Germany), EPD International (Sweden), or the BRE (UK).

A Digital Product Passport is a broader data structure mandated under CPR 2024. It must contain environmental data, but also Declaration of Performance data, product identification, substances of concern information, and more. Think of the DPP as a superset: the EPD provides one critical component - the environmental layer - but the DPP requires several additional layers that an EPD does not cover.

The relationship is complementary, not competitive. Your EPD does not become obsolete when the DPP arrives. Instead, it becomes one of the primary data sources feeding into your DPP.

What Your EPD Already Provides

A valid EN 15804+A2 EPD contains a rich set of environmental data that maps directly to DPP requirements:

Environmental Impact Indicators

Your EPD declares the following impact categories across defined life-cycle stages (typically A1-A3 for cradle-to-gate, with optional stages through to end-of-life):

  • Global Warming Potential (GWP) - separated into fossil, biogenic, and land use components under A2
  • Ozone Depletion Potential (ODP)
  • Acidification Potential (AP)
  • Eutrophication Potential - freshwater, marine, and terrestrial under A2
  • Photochemical Ozone Creation Potential (POCP)
  • Abiotic Depletion Potential - minerals/metals and fossil fuels

These are precisely the environmental indicators that the DPP’s environmental sustainability section requires. If your EPD is current and A2-compliant, you have this data already verified and published.

Resource Use Indicators

EN 15804+A2 EPDs also report:

  • Use of renewable and non-renewable primary energy (as energy and as feedstock)
  • Use of secondary materials and secondary fuels
  • Net use of fresh water

Waste and Output Flows

  • Hazardous and non-hazardous waste disposed
  • Radioactive waste disposed
  • Components for reuse, materials for recycling, materials for energy recovery
  • Exported energy (electrical and thermal)

Product Description and Functional Unit

Your EPD includes a product description, the declared or functional unit, and reference service life information (where applicable). This contextual information helps frame the environmental data for DPP purposes.

What Your EPD Does Not Provide

Here is where the gap analysis matters. A DPP requires several categories of information that are not part of an EPD:

Declaration of Performance Data

An EPD contains no DoP data. It does not declare essential characteristics like fire reaction class, thermal conductivity, compressive strength, or acoustic performance. It does not reference the harmonised European standard under which the product is assessed, nor the AVCP system, nor the notified body.

This data exists in your Declaration of Performance - but your DoP and your EPD are typically separate documents, managed by different people, in different formats, with no structured linkage between them. The DPP requires both data sets to be unified.

Product Identification (GTINs and Unique Identifiers)

An EPD identifies the product by name and description, but it does not assign a GS1 GTIN or generate a unique product identifier suitable for DPP linking. EPDs are typically issued per product type or product group, not per individual SKU.

The DPP requires each product variant to have a unique identifier. If your EPD covers a product family (e.g., “insulation board, 50mm to 200mm thickness”), you will need to map that EPD to individual GTINs for each thickness variant.

Substances of Concern

EN 15804 EPDs do not systematically declare substances of concern. While some EPDs include limited information about hazardous substances (particularly where national programme operator rules require it), this is not a core EPD data element.

The DPP requires explicit declaration of SVHCs above 0.1% by weight and potentially other substances of concern as defined by CPR 2024 delegated acts. This data must come from your product composition records and supply chain, not from your EPD.

Machine-Readable Hosting Infrastructure

An EPD is published as a document - typically a PDF - on the programme operator’s registry. Even where machine-readable formats exist (such as the ILCD+EPD XML format used by some operators), the EPD itself is not hosted at a persistent URI linked to a specific product instance via a data carrier.

The DPP requires exactly this: a web-accessible, machine-readable data endpoint, linked to each product through a QR code or equivalent data carrier, accessible for the product’s entire service life.

Circularity and Recyclability Data

While EN 15804+A2 EPDs include end-of-life stage data (modules C1-C4) and benefits beyond the system boundary (module D), the DPP may require additional circularity information: recyclability classification, disassembly instructions, and recycled content percentages. Some of this overlaps with EPD data; some extends beyond it.

The Conversion Process

Moving from EPD to DPP is not a simple file format conversion. It is a data enrichment and integration exercise. Here is the practical process:

Step 1: Extract Structured Data from Your EPD

If your EPD programme operator provides ILCD+EPD format data, download it. This gives you the environmental indicators in a structured XML format that can be parsed and mapped to DPP data fields.

If your EPD is available only as a PDF, you need to extract the data manually. This means reading the tables in the PDF and entering the values into a structured format - a spreadsheet initially, or directly into your product information system. Every impact indicator, for every life-cycle stage declared, needs to be captured with its correct unit and value.

This is tedious but essential. A DPP cannot reference a PDF - it must contain the actual data values in its machine-readable structure.

Step 2: Structure Your DoP Data

Separately, extract and structure the data from your Declarations of Performance. For each product:

  • Product type identifier and intended use
  • Reference harmonised standard (hEN) or European Assessment Document (EAD)
  • AVCP system
  • Essential characteristics and their declared performance values (with units, classes, and test methods)
  • Notified body identification (where applicable)

Map this data into the same product information structure as your EPD data.

Step 3: Assign Product Identifiers

Register GTINs for each product variant through GS1 Ireland. Map your EPD coverage to your GTIN catalogue - which GTINs are covered by which EPD? If one EPD covers a product group, you need to determine whether the environmental data applies uniformly across all variants or whether variant-specific data is needed.

Step 4: Compile Substances of Concern Data

For each product, compile a substance inventory. Engage your raw material suppliers for full composition data. Cross-reference against the REACH Candidate List to identify any SVHCs present above 0.1% by weight. Document this for each product variant.

Step 5: Integrate into DPP Schema

Combine the environmental data (from EPD), performance data (from DoP), identification data (from GS1), and substance data (from your composition register) into the DPP data schema. The exact schema will be defined by CPR 2024 delegated acts, but the data categories are well understood.

The output is a structured data file - likely JSON-LD - for each product, containing all required data fields populated with verified values.

Deploy the DPP data to a hosting infrastructure that provides persistent URIs. Generate GS1 Digital Link URIs for each product. Create QR codes encoding these URIs. Apply the QR codes to your products, packaging, or documentation.

Test the full chain: scan the QR code, reach the URI, retrieve the DPP data, verify it is complete and correct.

Why EPD Holders Are Well Positioned

Despite the gaps listed above, manufacturers with current EPDs have a genuine competitive advantage in DPP compliance:

The hardest data to obtain is already done. An LCA is the most resource-intensive data input to a DPP. It requires specialist expertise, it takes months, and it costs thousands of euros. If you have an EPD, you have already invested in this. Manufacturers without EPDs face this entire process before they can even begin DPP data assembly.

Your data has been third-party verified. EPD data is independently verified by an accredited verifier. This gives your environmental data a level of credibility and auditability that aligns with the DPP’s requirements for trustworthy product data. Self-declared environmental data would not carry the same weight.

You understand the data landscape. Organisations that have been through the EPD process understand LCA methodology, EN 15804 data structures, and environmental impact indicators. This knowledge transfers directly to understanding DPP requirements. You are not starting from zero.

Your EPD programme operator may offer DPP services. Several EPD programme operators are actively developing DPP-adjacent services - structured data exports, API access, machine-readable EPD registries. Check with your programme operator about their DPP roadmap. You may find that the bridge from EPD to DPP is shorter than expected.

Addressing the EN 15804 to DPP Data Gap

There are specific technical areas where EN 15804 EPD data and DPP data requirements do not perfectly align:

Granularity differences. EPDs are often issued for product groups or generic products. DPPs may require product-variant-level data. If your EPD covers a broad product range, you may need to either issue more granular EPDs or apply appropriate allocation rules to derive variant-specific environmental data from your group EPD.

Life-cycle stage coverage. Many construction EPDs cover only the product stage (A1-A3). DPPs may require data across a broader set of life-cycle stages. If your EPD is cradle-to-gate only, you may need to extend your LCA to include transport, installation, use, and end-of-life stages.

Data format alignment. The DPP data schema and EN 15804 data structure use different terminology and organisation in some areas. A mapping exercise is needed to translate EN 15804 indicator names, units, and stage nomenclature into the DPP schema vocabulary.

Temporal validity. EPDs have a defined validity period (typically 5 years). DPPs must reflect current data. Ensure your EPD is within its validity period and that the underlying LCA data still represents your current manufacturing process. If your production has changed significantly since the LCA was conducted, the EPD data may not be valid for DPP purposes.

The Practical Takeaway

If you have EPDs, treat them as a strategic asset for DPP compliance. They give you the environmental data layer that most manufacturers will struggle to obtain. Your task is now to build the additional layers - DoP data, product identification, substance tracking, and hosting - around that existing foundation.

If you do not have EPDs, obtain them. They are not merely a marketing tool or a voluntary green credential. Under CPR 2024, the environmental data they contain becomes a regulatory requirement. The EPD is the most efficient vehicle for generating that data in a verified, standardised format.

The bridge from EPD to DPP is real and achievable. It requires structured effort, but it is not a rebuild from scratch. For a broader view of how this fits into your overall compliance readiness, see our complete DPP readiness self-assessment.