Product carbon footprints (PCFs) are gaining momentum across the construction sector in Australia and New Zealand. They can help manufacturers understand greenhouse gas emissions, engage customers and identify where changes will have the biggest impact.
That is a good thing.
But increasingly, the discussion is being framed as though PCFs are a fast, simple and low-cost alternative to environmental product declarations (EPDs), which provide independently verified environmental information about products using standardised rules. In practice, particularly for building products, the advantages are often overstated.
Both PCFs and EPDs are built on the same life cycle assessment (LCA) foundation. Both require manufacturers to collect detailed data across the supply chain, including raw materials, manufacturing, transport and end-of-life scenarios. ISO 14067 (Carbon Footprint of Products) itself is based on the same ISO 14040 and ISO 14044 standards that underpin EPDs.
The reality is that once a company has assembled product-specific data for a credible PCF, much of the hard work needed for an EPD has already been done.
ISO 14067 already points towards PCRs
In fact, ISO 14067 explicitly requires the use of relevant product category rules (PCRs), which set the calculation rules for specific product groups, where they exist. For construction products, PCRs already exist across most major product groups. In addition, ISO 14067 is a normative reference in EN 15804, which is the core PCR framework for building products.
This means an ISO 14067-compliant PCF for a building product should follow the same rules that underpin EPDs, including:
- system boundaries
- declared or functional units
- allocation approaches
- recycling and end-of-life treatment
- biogenic carbon accounting
- data quality requirements
In construction markets where procurement teams and rating tools increasingly rely on comparable product data, consistency matters.
Comparability does not happen automatically. Two carbon footprints can only be fairly compared if they use the same calculation rules and assumptions. EPD programs already provide that structure through established PCR frameworks.
Ironically, many PCF approaches end up recreating the same governance structures and methodological rules that EPD systems already have in place.
The extra effort is often marginal
The claim that EPDs require dramatically more effort is also frequently exaggerated.
Once the core product data has been collected, the additional effort needed to calculate other environmental indicators is often relatively small, particularly when using the right LCA databases and software tools.
For many products, the real effort lies in gathering high-quality supplier and manufacturing data, building the LCA model and ensuring data quality. Whether the output reports one impact category or multiple categories often makes relatively little difference once the model exists.
Additional benefits of LCA beyond carbon
Carbon is critically important, but it is not the only environmental issue businesses, regulators, and specifiers are trying to manage.
The broader impact indicators included in EPDs can help identify hotspots related to:
- water use
- eutrophication
- acidification
- particulate emissions
- resource depletion
- land use and nature-related impacts.
These indicators help businesses understand environmental impacts beyond climate change. A carbon-only metric cannot show whether reducing emissions in one area may increase impacts somewhere else. A product with a low carbon footprint may still create significant impacts elsewhere in the value chain.
This broader perspective is becoming increasingly important as organisations begin preparing for nature-related reporting requirements and frameworks such as the Taskforce on Nature-related Financial Disclosures.
For many businesses, undertaking a full LCA and developing an EPD can support their understanding where nature-related hotspots and dependencies exist across the value chain. It helps organisations move from broad assumptions to product-specific insight.
Credibility and verification matter
Verification is another area where the distinction between PCFs and EPDs is often overstated.
Credibility comes from transparency, methodology and independent verification, not from the label used. EPDs require independent verification under the ISO 14025 framework. PCFs also need independent review if they are being used to support procurement decisions, reporting or public environmental claims.
The better question
None of this is an argument against PCFs. They are valuable tools and can play an important role in helping organisations start measuring and reducing emissions.
But for construction products, the idea that PCFs are fundamentally simpler, substantially cheaper or dramatically less data-intensive than EPDs does not always hold up under closer examination.
Rather than positioning PCFs and EPDs as competing alternatives, it may be more useful to recognise that they sit on the same technical foundation.
The question is not which label sounds simpler. The real question is what information decision-makers need, how comparable the results need to be, and whether the underlying data is robust enough to support confident decision
- Barbara Nebel is the CEO of thinkstep-anz
