Environmental product declarations (EPDs) are a key tool for ensuring the consistency, rigour and auditability of a product’s environmental claims.

Environmental reporting is not new and has often taken place on a voluntary basis to respond to consumer expectations. It has also been a feature of many governments’ responses to global warming, and more broadly, practices that contribute to environmental degradation, such as waste, soil and water contamination, and biodiversity loss.

The significant environmental impacts of the building and construction sector were noted at the inaugural Buildings and Climate Global Forum in March this year:

• The sector is responsible for over 34 percent of energy demand and around 37 percent of energy-related CO2 emissions;
• Global demand for raw materials is projected to nearly double by 2060, with construction materials set to dominate;
• The gap between the actual energy and climate performance of the building sector and the necessary pathway to achieve its decarbonisation and resilience continues to grow; and
• 100 billion tons of waste is generated from construction, demolition and renovation processes annually, with around 35 percent sent to landfills.

Australia recently passed ESG legislation requiring companies to report on climate change strategy and risk management. This initially applies to larger companies but will gradually include smaller ones based on turnover and employee count. In regard to sectors like construction, this entails greater consideration for responsible sourcing of materials, and other inputs into goods and services. While the primary focus is on transparency, it is conceivable that targets will eventually be set to provide a stronger framework for auditing Australia’s progress on its Paris commitments.

In the building space, this may be supplemented by measures in the National Construction Code (NCC). In June of this year, federal, state and territory building ministers requested the Australian Building Codes Board “… to include a voluntary pathway in NCC 2025 for commercial buildings to measure and report on embodied carbon utilising the National Australian Built Environment Rating System (NABERS) method. Ministers also asked the ABCB to investigate how to incorporate and fund inclusion of a future minimum standard for embodied carbon in NCC 2028 to further support Australia’s transition to net zero.”

Achieving the second of these actions would involve the development of a quantified Performance Requirement in the NCC, as well as a robust attestation mechanism for verifying claims and determining responsibility for compliance. It would also likely necessitate the development of a technical standard, for which consideration could be given to the NCC/ASHRAE 240P Evaluating Greenhouse Gas (GHG) and Carbon Emissions in Building Design, Construction and Operation standard under development.

Environmental Product Declarations
In Australia, EPDs have become quite fashionable for market leaders in different sectors of the economy as a means of distinguishing companies from their competitors, responding to consumer demands, or enabling other actors in the supply chain to report on inputs to their products.

The mainstream building industry has been slow to adopt EPDs as there is no legal requirement, particularly as most of the sector does not fall under the initial thresholds of ESG legislation. However, in light of the future lowering of these thresholds, and the prospect of more direct accountabilities under a future edition of the NCC, EPDs may emerge as an important mechanism for demonstrating compliance with environmental regulations.

EPDs reporting measures can include disclosure of resource and energy use, including embodied carbon, and incorporate the outputs of a life cycle assessment (LCA) that details the environmental impacts of a product across its life stage. The latter is associated with a product’s ability to be repurposed and recycled at the end of its service life, and the former is associated with the upfront carbon generated by mining or harvesting of a raw material, the processes involved in manufacture or fabrication, and installation in a building. Transportation-related emissions are also included throughout the supply chain.

In circumstances where a whole of building life cycle assessment (WBLCA) is involved, which currently would be voluntary, EPDs with associated LCAs would be required for each input to enable aggregation for the scale of a building. In such a circumstance, those responsible for the building would need to collect the necessary data from individual product suppliers.

The international infrastructure for EPDs revolves around having Program Operators accredited to ISO 14025, under which Product Category Rules (PCRs) are established, LCAs and EPDs are developed for verification by independent third parties. More information about these arrangements can be found at: Environmental Product Declarations – ICC Evaluation Service, LLC (ICC-ES).

Looking Ahead
It is anticipated that ESG legislation will continue to expand internationally. This year, the European Union is introducing regulations requiring all products sold in the EU to hold a digital product passport, which amongst other things, provide transparent data on environmental practices. This is also indicative of increasing sophistication in documentation for claims verification. Building products are currently scheduled to be included in 2027 based on a construction products listing register.

It is important to bear in mind that at some point, those who are exporting into jurisdictions that have ESG, digital product passports or similar requirements will likely need to conduct the necessary attestations to enable companies who import and supply products in those markets to comply with climate reporting requirements.

Endnotes:

[1] Source: Declaration de Chaillot, Paris France, 3/8/24

[2] Source: https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/Bills_Search_Results/Result?bId=r7176

[3] Source: Building Ministers Meeting Communique, Canberra Australia, 6/21/24

[4] Source: EU’s Digital Product Passport: Advancing transparency and sustainability | data.europa.eu

By Neil Savery, Managing Director, International Code Council Oceania

Neil is the Managing Director of International Code Council Oceania, part of the International Code Council (ICC), a global provider of building safety solutions, including model building codes and a suite of practical solutions for regulators, practitioners, and manufacturers involved in the building sector.

Prior to joining the ICC, Neil was the Chief Executive of the Australian Building Codes Board and has previously led planning and regulatory bodies for a number of states and territories. He has also served as the President of the Planning Institute of Australia

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