How Environmental Product Declarations automation unlocks competitive advantage in the US

The US construction and materials sectors have entered a new compliance era in 2025. Federal and state policies have turned once-voluntary Environmental Product Declarations (EPDs) into regulatory requirements that directly impact market entry and positioning.

In this new landscape, competitive construction and materials leaders can no longer rely on ad‑hoc processes or one‑off consultants. Long-term success hinges on scalable, software‑driven EPD workflows that are verifiable against evolving standards and repeatable across entire product portfolios.

Navigating the new EPD compliance landscape

EPDs used to be a bonus for early movers. They’ve historically helped manufacturers that invest in cleaner production stand out in sustainability-focused projects. But recent regulatory changes have inverted this dynamic.

Instead of offering an optional edge, EPDs now determine who can even show up to compete. EPDs control access to federally backed projects and public building work. To even qualify for the GSA’s federal building contracts, manufacturers must provide EPDs proving their products rank in the top 20-40% cleanest in their material category.

At the state level, momentum around Buy Clean policies means that EPDs for products sold across states must satisfy varying GWP thresholds, reporting formats, and material categories — complicating scale.

At the same time, the rules behind EPDs themselves are getting stricter and more dynamic. The EPA is tightening the criteria for PCRs — the Product Category Rules that underpin EPDs — for its low-carbon label. As these standards evolve, manufacturers must continuously monitor compliance to maintain credibility with green building certification programs, corporate sustainability buyers, and environmentally conscious customers.

Why current EPD development approaches fall short

Staying competitive at scale depends on ISO-compliant EPD documentation that reflects production processes, energy sources, and transportation logistics for every facility.

The operational overhead of accomplishing this multiplies quickly. Manufacturers juggle hundreds of product variations across multiple sites, and each combination requires its own EPD. If specific information proves unavailable — like supplier data on the impact of raw materials — operators must fall back on generic industry averages.

Compiling all this information is just the beginning. Third-party verification adds months to the timeline, often requiring additional documentation and clarifications on data sources. Program operators like UL Solutions and ASTM International add another layer of complexity, as each maintains its own submission portal with distinct format requirements and review timelines.

Traditional EPD approaches share a common thread: they can’t maintain the speed and accuracy that evolving regulations demand across hundreds of facility-specific EPDs.

In-house development

The appeal of in-house EPD management is clear: familiar tools and direct control over product data — at a perceived cost savings. However, this approach carries a hidden operational drain.

Each EPD requires manual data collection from scattered sources — energy bills, supplier documentation, transportation logs, production records — to build accurate LCA calculations. These steps demand significant time and divert capacity from process optimization. And, if the supply chain or production processes change, the entire data collection process starts over.

The stakes are too high to accept this risk. A single reporting error — whether it’s a miscalculated emission factor or an incorrect material specification — can delay market access by months, triggering costly rework cycles and material replacements.

Consultants and LCA experts

Many organizations, lacking in-house LCA experts, hire consultants to model products, interpret PCR requirements, and navigate the EPD submission processes. This approach provides immediate access to specialized knowledge — but comes with steep and recurring costs.

Just to start, consultants typically charge between $10,000 and $50,000 per EPD. These fees then reset every time an EPD expires or needs to be updated based on PCR, facility, and policy changes.

Beyond the direct costs, limited consultant availability and lengthy revision cycles delay completion and market readiness. Late submissions lead to financial penalties or disqualify products from time-sensitive opportunities, while rushed work or understated metrics push compliant products above GWP thresholds, resulting in market exclusion.

Generic EPDs

Industry‑average EPDs are often the lowest‑cost way for manufacturers to get baseline EPD coverage, but they trade off speed of deployment and competitive differentiation.

These generic EPDs lack the accuracy and specificity that buyers and regulators increasingly expect. Procurement teams using the EC3 (Embodied Carbon in Construction Calculator) database consistently favor facility-specific data. Generic EPDs are also ineligible for LEED material credits, shutting out these manufacturers from sustainability-driven projects.

With GWP thresholds tightening and “top-performer” procurement policies expanding, these alternatives also become operationally risky. Overstated metrics can damage credibility with regulators, contractors, and investors, undermining partnership and funding opportunities.

Some jurisdictions go further by explicitly restricting generic EPDs. Washington State, for example, limits the use of industry-average data when upstream processes account for more than 80% of a product's total impact.

Commercial LCA and EPD software

Off-the-shelf LCA and EPD tools promise efficiency and consistency, but often fall short of the pace, precision, and adaptability that today’s materials market demands.

Commercial software requires significant upfront investment and ongoing licensing fees — but the expense doesn’t translate to ease. These tools still rely on substantial manual data input and specialized expertise to align configurations with evolving PCRs, emission factors, and jurisdiction-specific requirements.

In the end, teams are forced to bolt these platforms onto legacy systems and spreadsheets, recreating the same bottlenecks they were seeking to eliminate: high risk of data errors, version control issues, and gaps in audit trails.

Unlocking EPD success through AI-powered automation

To stay competitive, operators are rethinking EPD management from the ground up with purpose-built, AI-powered EPD systems.

By centralizing fragmented data and applying intelligent algorithms, AI-powered EPD systems generate compliant draft EPDs without complex configurations, manual data work, or recurring consulting fees.

Beyond compliance, this granular operational visibility enables optimization of inefficient, carbon-intensive processes, directly supporting margin and performance enhancements.

And this approach is built to last. AI-driven platforms continuously track shifting federal and state rules, so when PCRs are revised, state limits tighten, or new EPA criteria phase in, they automatically flag affected EPDs for updates. They also prioritize those updates based on upcoming bid deadlines, helping manufacturers avoid missed submission windows and keep their portfolios ready for every opportunity.

Cogna powers EPD automation at scale

Through its AI-powered software factory, Cogna delivers AI-driven EPD solutions built for the realities of the US materials sector.

Cogna partners directly with those closest to EPD operations to map existing workflows and data sources, then creates AI applications tailored to product categories, facilities, and reporting needs.

Every Cogna-built tool is engineered to integrate seamlessly with manufacturers’ existing systems. In a deadline-driven, risk-averse industry, this strategy ensures quick and reliable implementation and keeps companies compliant and fully operational.

Clear documentation trails and PCR-aligned calculations ensure submissions are verification-ready from the start, smoothing the third-party review process. And as regulations evolve, Cogna’s expert team ensures solutions stay current, secure, and reliable — without IT lift or consulting arrangements.

Cogna enables operators to focus on what matters: production optimization and market growth rather than software maintenance.

Ready to turn EPD compliance into a competitive advantage? Let’s talk.