Low-carbon construction and building product EPDs: what manufacturers need to know
The Finnish Building Act’s obligation to declare the carbon footprint of new buildings entered into force on 1 January 2026. Designers need product-level data, and the question lands on the building product manufacturer’s desk: “Does your product have an EPD?” This article explains what is at stake and where a manufacturer should start.
Why low-carbon construction now concerns the manufacturer
Calculating a building’s carbon footprint has moved from a production issue to a statutory requirement in Finland.
The Building Act requires the declaration of a new building’s carbon footprint starting from 1 January 2026. The obligation applies to new building permit applications and covers building types such as terraced houses, apartment buildings, offices, commercial buildings, and hospitals. The obligation does not apply to single-family houses, renovation construction, cultural buildings, ice halls, large warehouses, or industrial buildings. The exact scope of application should be confirmed on the Ministry of the Environment website or with the project designer.
The EU Taxonomy guides investors to classify as sustainable only buildings whose environmental impacts have been documented. This particularly affects large real estate investors, who require product-specific EPDs for whole-life-cycle calculations of buildings.
Property owners’ own targets (SBTi, CSRD, customer requirements) add pressure to identify the emissions of every construction project. A real estate investor who has committed to an SBTi target needs product-level data from its supply chain and can no longer be satisfied with generic averages.
Tools used by designers and contractors (e.g. One Click LCA, Bionova) retrieve product data directly from EPD registries. If your product is not found in a registry, it cannot be selected in these tools using real figures.
In practice, this means that a designer calculates the building’s carbon footprint and needs product emission data to do so. If the manufacturer does not have an EPD, the designer uses a generic factor (the most common source is the Ministry of the Environment’s Emissions Database), which is generally conservative and unfavourable for the manufacturer. An EPD is a way to get your product’s own, real emission figure into the building’s calculation.
EN 15804: the European standard for building product EPDs
EN 15804 is the European standard for environmental product declarations (EPDs) for construction products. It is in practice the core PCR for building products and ensures that EPDs from different manufacturers are mutually comparable.
The standard defines:
- Impact categories to be reported: GWP (climate change), AP (acidification), EP (eutrophication), ODP (ozone depletion), POCP (photochemical ozone formation), ADP (use of fossil resources and minerals), and additional indicators (water, waste, secondary materials).
- Life cycle modules to be reported. EN 15804 divides the life cycle into modules:
- A1–A3 product stage (raw materials, transport to factory, manufacturing).
- A4–A5 construction stage (transport to site, installation).
- B1–B7 use stage (use, maintenance, repair, energy and water).
- C1–C4 end of life (demolition, transport, processing, disposal).
- D recycling and reuse benefits (reported separately).
EN 15804+A2 (2019/2021) is the current version, which tightened requirements regarding, for example, biogenic carbon, impact assessment models (EF 3.x), and the mandatory nature of modules. Its relationship to ISO 14025 is that EN 15804 is the core product category rules for construction products developed under ISO 14025.
EN 15978: building-level assessment
A product EPD answers the question “how many emissions does a single product have.” EN 15978 answers the question “how many emissions does the entire building have.” This is the standard for assessing the whole life cycle of a building.
The connection is clear: a building-level assessment in accordance with EN 15978 uses product EPDs in accordance with EN 15804 as inputs. The designer calculates the impact of each product across the building’s life cycle and sums them together.
This is why designers and contractors are asking for product EPDs more and more frequently: without them, the entire building calculation is based on generic averages that do not distinguish between different products.
The basics and general content of EPDs are covered in a dedicated article: EPD: what it is and why it is requested.
The Building Act and low-carbon guidance in Finland
The Finnish Building Act requires the declaration of a new building’s carbon footprint. The practical process:
- The designer calculates the building’s carbon footprint in accordance with the Ministry of the Environment’s guidance.
- Product EPDs are used in the calculation when available.
- If a product EPD is not available, the generic factor from the Emissions Database is used. The generic factor is typically unfavourable because it is designed to be conservative and to cover the spread across the market.
- The building’s carbon footprint is declared in an environmental report submitted with the building permit application.
The low-carbon guidance does not yet set a binding limit value, but the obligation to declare the figure is shifting choices towards lighter and lower-emission products. In subsequent phases of the legislation, limit values will likely be introduced.
From the manufacturer’s perspective, this means: if your competitor has an EPD and you do not, the designer sees the competitor’s product with real (usually more favourable) figures and your product with conservative generic factors. This affects product selection.
The EU Taxonomy and building products
The EU Taxonomy is the EU’s classification system that defines which economic activities are considered environmentally sustainable. For buildings, the taxonomy sets criteria for energy efficiency and whole-life-cycle environmental impacts.
Taxonomy requirements are moving to the product level. Real estate investors and financiers expect the products used to be documented and that product-specific EPDs can be used in taxonomy assessments of buildings. This particularly concerns large construction projects and green loans.
In practice, an EPD is increasingly a prerequisite for participating in low-emission construction projects where the financier requires taxonomy compliance. Clients are already asking at the tender stage whether the product has an EPD and whether it can be found in a registry; without an EPD, the tender may not advance to the next stage.
Another taxonomy-related dimension is the classification of properties as low-carbon. Only buildings whose whole-life-cycle emissions have been calculated and that fall below agreed limit values can obtain green financing on more favourable terms. This creates structural pressure within the construction industry to use products that have an EPD.
Where a manufacturer should start
An EPD programme is best built in stages. A useful starting order:
1. Prioritisation. List the 3–5 products about which customers most frequently ask for emission data. Start with those. An EPD programme should not cover the entire product portfolio at once; begin where demand is greatest.
2. Data collection preparation. Verify that the product recipe (bill of materials) is available, that the manufacturing energy metrics can be allocated to the product, and that transport data are accessible.
3. PCR selection. The correct PCR is chosen for the product group (either the EN 15804 core or a product-group-specific sub-PCR). Different programme operators have their own PCR versions to some extent, which should be compared.
4. Partner selection. An LCA consultant performs the calculation, writes the report, and coordinates verification. A good partner knows the PCRs for construction products, can discuss with the verifier, and takes the project through to publication. NGS handles all of this: LCA and EPD service.
5. Verification and publication. After review by an accredited verifier, the EPD is published in the programme operator’s database. From this point on, designers can find your product with real figures.
6. Update. An EPD is typically valid for 5 years. The update cycle should be planned from the outset, because product recipes and energy sources change over time.
One practical tip: during data collection for the calculation, it is worth gathering information that is also useful for product development (e.g. which raw material is driving emissions), so that the EPD does not remain merely a certificate but also supports product development towards a lower-carbon portfolio.
Frequently asked questions
Does the Building Act require an EPD to be produced?
Not directly. The legislation requires the declaration of a building’s carbon footprint, not a product-specific EPD. If no EPD is available, the designer uses the generic factor from the Ministry of the Environment’s Emissions Database, which is generally conservative and unfavourable for the manufacturer. In practice, an EPD is the way to compete effectively in this calculation.
What is the difference between EN 15804 and EN 15978?
EN 15804 is the standard for a product EPD (the impacts of a single product). EN 15978 is the standard for assessing the building’s entire life cycle (the impacts of the building). EN 15978 calculations use EN 15804 EPDs as inputs.
What do the life cycle modules A1–A3 mean?
A1 = raw material extraction. A2 = transport from supplier to factory. A3 = manufacturing at the factory. Together these are the manufacturing emissions of the product (cradle-to-gate). A4–A5 cover the construction stage, B1–B7 the use stage, and C1–C4 end of life.
In which database is a building product EPD published?
The most common programme operators in Finland and the Nordic countries are EPD International (EPD System), RTS EPD, and the German IBU. EPDs from different operators are generally accepted alongside each other in construction projects.
How long does it take to produce a building product EPD?
Typically 4–6 months from preparation to publication. Data collection is usually the bottleneck. If the product family is very homogeneous and data are readily available, the project can be completed more quickly.
Can multiple products be covered by a single EPD?
Yes, if the products belong to the same product group and are sufficiently similar. This is called an average EPD or product family EPD. The rule is that the variation between products in the impact categories must not exceed a defined limit (typically 10% in GWP). This is an efficient way to cover a portfolio cost-effectively.
Is an EPD the same across all programme operators?
The content is, because all follow EN 15804 and ISO 14025. The layout, publication method, and specific details of individual PCRs vary. In Finnish projects, RTS EPD is well known and widely found, whereas EPD International (EPD System) is more widely used internationally. Which one to choose depends on the target market.
Do you manufacture building products?
We produce EPDs in accordance with EN 15804 from data collection through to verification. You receive a result that allows designers to calculate your product’s contribution to building emissions with real figures, not a generic average. Send us a list of the products about which customers ask most frequently. Those are the natural starting point.
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