The Biden Administration, partially in response to goals and requirements set by Congress, is pressing infrastructure owners and builders to decrease the embodied carbon associated with building and operating highways, locks and dams, airports, water and wastewater treatment systems, mass transit and anything else bought by or paid for using funds provided by the federal government. This use of the federal purse to drive reductions in emission of climate warming gases is intended to spur similar action in the private sector.

Congress has specifically identified environmental product declarations (EPDs) as the means of communicating information about the climate impacts associated with construction products and materials, and in the Inflation Reduction Act of 2022 provided the Environmental Protection Agency (EPA) with $350 million to develop EPD programs and encourage their use.

While the use of EPDs in this way presents challenges, as I’ll describe later, it seems likely that composites manufacturers will need to provide these documents for their products.

We’ve already heard from composites manufacturers that customers are asking for EPDs, including for products for non-government funded projects like electrical distribution systems and commercial buildings.

Content and Use of EPDs

An EPD is a document prepared in compliance with ISO standards that presents information about a product’s environmental impacts. Here are some of the important elements of an environmental product declaration:

  • The scope identifies the products that are covered by the document. An EPD can present information that is an average across multiple producers of a product or for the product produced by one company at one location.
  • The life cycle stages for which environmental impacts estimates are provided. An EPD can include information on the full life cycle of a product, including product use and at end-of-life, but the majority of EPDs provide only cradle-to-gate impact estimates (including extraction of resources from nature, upstream processing and transportation, and manufacture of the product).
  • A functional or descriptive unit that defines the amount of product to which the environmental impacts data apply. For example, an EPD for glass fiber insulation could provide an estimate of the climate impacts associated with the production of 1 kg of the product (a descriptive unit) or with the amount of the product needed to provide a certain amount of thermal insulation in a standardized test (a functional unit).
  • Estimates of environmental impacts within the scope and specified life cycle stages. An EPD for a product is likely to include, for example, estimates of the amount of climate warming gases associated with the specified life cycle stages for the products included in the scope of the document.

The purpose of an EPD is to convey information that will allow a downstream user to compare the environmental impacts of two or more products or materials that are being considered for a project.

For instance, a contractor building a highway bridge may have two sources of steel rebar potentially suitable for the project and want to consider the amount of climate warming gases associated with the manufacture of each supplier’s product along with other information, such as price and availability. EPDs allow a comparison of the environmental impacts of each of the suppliers’ products, which can be considered as part of the material or product selection process.

Preparation of an EPD

The EPD preparation process identified in the relevant ISO standards starts with a product category rule (PCR) that specifies how environmental impacts data are to be collected, analyzed and presented in an EPD.

A PCR is a consensus standard developed by a committee of industry members and external stakeholders (such as researchers and product end users) and guided by a program manager who ensures compliance with the relevant standards, manages independent verification of the draft document and then makes the final PCR available to the public on its website.

A PCR specifies how a life cycle analysis (LCA) is to be prepared for the product for which an EPD is needed. An LCA is a summary of energy use and environmental impacts associated with a product’s manufacture, use and/or end-of-life, depending on the scope.

Data from an industry average LCA for 1,000 pounds of an open molded composite product is provided in figure 1. As described in an applicable PCR, these data would be presented in an EPD in a format and with other information that facilitates product comparisons and other uses.

Problems with EPDs

Congress decided that EPDs are to be used to drive reductions in climate warming gases associated with infrastructure construction. That doesn’t mean that EPDs are suitable for this job.