Greenhouse gases can be emitted across various stages of a product’s life cycle, from raw materials and manufacturing to disposal. These emissions are often referred to as a product’s “embodied emissions.” Currently, the most common way of reporting product-level data on embodied emissions is through an environmental product declaration (EPD), a standardized document providing quantified information on environmental impacts, as well as use of materials and resources, across the life cycle of a product. EPDs rely both on international standards to provide a high-level framework and on more granular product-level rules developed by stakeholders.

To date, nearly all policies requiring companies to report embodied emissions using EPDs have accompanied initiatives to advance clean public procurement at the state level. The federal government and Congress have also taken significant steps since late 2021 to broaden Buy Clean—a set of policies designed to prioritize procurement of lower-carbon materials—nationally. EPDs are relevant to other climate-related policies as well, including product standards, building codes, and potentially trade policies. There are numerous ways, however, that EPDs and the data they rely on fall short, presenting hurdles to making product-level reporting more useful and widespread. These include significant gaps in primary data at various stages in products’ life cycles; the inability to compare products that develop EPDs based on different reporting rules, databases, and software tools; the fact that product-specific EPDs are still often unavailable; and a lack of uniformity in EPD rules across states and the federal government. 

There are tangible steps that governments and stakeholders that develop reporting rules can take to overcome the challenges and shortcomings associated with EPDs, including:

• Updates to the rules for EPD development to address data gaps: requiring more primary data and more reporting on post-production life cycle stages where relevant.
• Standardization to improve comparability and consistency: improving standardization on the use of secondary data and life cycle analysis tools, enhancing efforts to improve the quality and availability of secondary data in the United States, and working to achieve greater consistency on EPD requirements in state and federal Buy Clean initiatives.
• Incentives to increase EPD availability: providing education, assistance, and financial incentives to manufacturers (especially small and mid-size manufacturers) to support their production of EPDs. EPD availability can also be boosted through the expansion of Buy Clean laws. 

In addition, the private sector will need to engage suppliers more actively to improve the availability of product-level data, exerting influence where possible but also working cooperatively with suppliers and through industry groups and initiatives. One opportunity to expand product-level reporting is through approaches that focus narrowly on embodied emissions (as opposed to comprehensive assessments of environmental impacts), but these approaches still require product-level reporting rules to allow comparability between products. There are also efforts underway to expand the availability of product-level data by harnessing technology, supplier engagement, and simplified reporting, with some platforms emerging that focus on greening private-sector value chains.