ECOS | Environmental Coalition on Standards

21 March 2025

Securing robust Environmental Product Declarations

There is increasing industry interest in the use of Chain of Custody (CoC) models. What are these models? Which are problematic? How can they be made better?

This paper looks at CoC models, particularly those based on credits rather than actual physical flows of inputs and outputs with specified characteristics, such as biobased or the use of secondary materials.

These ‘mass balance’ approaches are already common in sectors such as chemicals, plastics, and metals. There is also interest in using such credits as the basis for Life Cycle Assessments (LCAs) and Environmental Product Declarations (EPDs) in the construction sector.

  • There are a number of concerns to address, particularly: 
    Not complying with requirements set out in core EPD rules defined in EN15804+A2 such as co-product allocation, EPD comparisons, and inclusion
    of carbon offsets;
  • Clashing with current and upcoming EU laws;
  • Creating barriers to decarbonisation and innovation;
  • Endangering fair choices and leading to greenwashing;
  • Misleading end-users of EPDs (such as architects or consumers) and reducing the credibility and reliability of EPDs;
  • Leading to problematic digital data available at building level, gambling the management of circularity with products not containing what has been claimed

Learn more about how these concerns can be addressed by reading the full paper.

Download the document

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