This credit, like the other two Materials & Resources credits under the “Building Product Disclosure & Optimization” (BPDO) umbrella, has one point for transparency and a second point for reducing impacts.

The intent behind this approach is that there is not enough good data available in the market on the environmental footprint of products, and that before we can expect the industry to improve, we have to get better at measuring the things we care about. That’s why the first point rewards teams for using products that come with data about their environmental impacts (such as environmental product declarations, or EPDs), even if those impacts are bad. The second point rewards teams for using products with lower impacts—at least that’s the goal.

Option 1: Just Use 20 Products with EPDs

Option 1 outlines several ways that products can contribute to achieving this point, but there is little reason to bother with some of them. Yes, you could try to find products that have life-cycle assessment data but no EPDs, but you’d need a total of 80 of those to achieve the point. Or, you can use products associated with industry-wide EPDs—but you’d need 40.

There are enough product-specific EPDs available that most projects should have little trouble finding the 20 that are required to earn the point. You might even find it possible to get to 40, and claim an exemplary performance innovation point.

An exception to this advice is for tenant improvement projects that are keeping finish materials to a minimum—if you’re not using that many products in the project, it can be hard to get to 20 with EPDs. But just by switching things up a little you can still make this work, since you’re allowed to include multiple products from any one manufacturer, as long as at least five different manufacturers are represented. 

If you do want to include some industry-wide EPDs in your mix (keeping in mind that you need twice as many of those to get to 20), be sure that they clearly identify the manufacturer of the product you’re using as a participant in the program—many industry-wide EPDs don’t list participating companies.

What Counts as a Separate “Product”?

As soon as USGBC introduced the idea of earning a point based on how many products meet the criteria, questions arose about what counts as a separate product. If you use two different colors of the same paint, is that one product or two?

Since then, USGBC has issued guidance that makes things pretty clear—at least in most situations (it’s hard to anticipate every situation that might emerge!). If two versions of a product differ only in appearance, they only count as one product, not two. So the two paint colors—no luck there. But if they differ in function, then you’re ok. If those two paints have different gloss levels—like a flat white wall paint and a semigloss for trim—then you can count them as two products.

Similarly, if you’re buying a set of windows that are all the same except for their dimensions, they would only count as one product. But if some of them are operable and others fixed, then you can count each type as a separate product—up to the cap of five per manufacturer.

When it comes to assemblies, or things made up of components, the basic question to ask is “how is delivered to the job site?” A window is made up from a lot of different components: insulated glazing unit, spacers, frame, nailing fins—but it’s just one product, unless you’re assembling that window onsite by building your own frames. In that case the materials used to make the frames and the glazing unit would each count as separate products.

What’s an Environmental Product Declaration (EPD)?

EPDs, formally called “Type III Environmental Product Declarations” by ISO, are independently verified reports based on life-cycle assessment (LCA) studies. The LCA studies must have been conducted according to a set of common rules (“product category rules,” or PCRs) for each product category and then peer-reviewed.

At the heart of the EPD process are “program operators”—organizations that ensure that the EPDs meet the various requirements.

UL Environment is the leading program operator in the U.S., responsible for the great majority of EPDs that have been published to date. These include generic, industry-wide EPDs for the American and Canadian Wood Councils as well as product-specific EPDs for several carpet companies and other major manufacturers. Other organizations serving as program operators include NSF International and ICC Environmental Services (ICC-ES), a subsidiary of the International Code Council.

These program operators don’t do the actual LCA studies behind the EPDs. They simply ensure that the studies follow the appropriate product category rules and that they’ve been translated properly into the EPD format. Because EPDs are relatively new in the U.S., the program operators have been busy sorting out the product category rules while trying to meet ISO’s stipulation to avoid creating duplicate PCRs within a product category. When program operators attempt to produce the first U.S.-based EPDs in a category, they can either create a PCR from scratch—as ICC-ES has done for pressure-treated wood—or adapt one from Europe, which has been UL Environment’s preferred approach.

Make Sure Your EPDs Qualify

EPDs from well established program operators generally meet LEED’s requirements, but it’s good to know what those requirements are and confirm that they do. Unless you’ve studied the relevant ISO standards and EN 15804 (which governs the product category rules process), you might find the details a bit overwhelming, so here are the basics:

• You can provide either a full EPD or a summary report with a link to the full EPD. Whichever you upload, it has to list the manufacturer name and EPD program operator, and a product description.
• Environmental life-cycle assessment—the science behind the EPD—relies on a method for quantifying environmental impacts. The EPD has to say which standard impact assessment was used—typically either TRACI or CML.
• Life-cycle assessments vary in how much of the product’s life cycle they cover. For LEED, the scope has to be at least “cradle-to-gate,” meaning that it has to include the extraction of raw materials and cover all the steps up to the product’s final manufacture. “Gate” in this case refers to the gate of the factory, meaning the product is ready to be distributed.
• There is a set of official information that’s included on every qualifying EPD, including:
  • Who the program operator is
  • When the EPD was published, and how long it’s valid
  • Which product category rule (PCR) it follows
  • Who reviewed the PCR
  • Who independently verified that the EPD meets ISO 14025
  • Who verified that the life-cycle assessment behind the EPD conforms to ISO 14044 and the stated PCR
• LCA results for the product have to cover at least the six basic environmental impact categories:
  • global warming potential (greenhouse gases), in CO2e;
  • depletion of the stratospheric ozone layer, in kg CFC-11;
  • acidification of land and water sources, in moles H+ or kg SO2;
  • eutrophication, in kg nitrogen or kg phosphate;
  • formation of tropospheric ozone, in kg NOx, kg O3 eq, or kg ethene; and
  • depletion of nonrenewable energy resources, in MJ.

It makes things easier for the reviewers (and therefore they might be more inclined to give you the benefit of the doubt), if you take the trouble to highlight the required information on whatever files you submit.

This might seem obvious, but quality-control is a problem with a surprising number of LEED submissions. Be sure to check that the EPD or summary you provide matches the product listed in the form (and in the materials calculator), and if you link to full EPD make sure the link goes to the same product.

Option 2: Good Luck Beating the Benchmark

Option 2 has a really tough threshold to meet: at least 50% of all products and materials in a project, by cost, have to comply. It doesn’t help that USGBC has yet to approve any industry programs as supporting this option. To make things even harder, structure and enclosure materials can only count for up to 30% of the overall materials cost (unless you itemize your entire bill of materials and show that on your project structure and enclosure represents more than 30%).

So it’s hard to see how any project can earn this point.

If you want to try, however, USGBC has introduced one pathway: you can count any product that comes with a product-specific EPD that shows an improved environmental footprint.

The “improved” environmental footprint can be in comparison to one of two benchmarks:

• an older EPD of the same product (showing improvement over time), or
• an industry-average EPD, as long as the product manufacturer was also a participant in creating the industry average version.

The comparison has to show that the product beats its benchmark in at least three of the six environmental impact categories that have to be included in an EPD.

As with the other BPDO credits, you can get extra credit for using local materials, but only if they’re both extracted and processed within 100 miles (160 km) of the project site.

Where to find LEED-compliant products

Currently, the most extensive list of EPDs openly available in the U.S. is in UL’s SPOT database, which lists products with EPDs along with many other certified claims. Others can be found on the ICC-ES website, on NSF’s website and scattered around the Internet.

What’s New in the LEED v4.1 beta

• Getting to 20 products was doable for a typical whole building but daunting for a tenant fit-out or warehouse that used only a small selection of products. Those simpler project types now need only ten products from three manufacturers.
• The previously unachievable Option 2 is completely revised to make it much easier. The thresholds that were out of reach have been cut drastically, from 50% and 25% down to 10% of products by cost. You also now have the option of skipping the “by cost” calculation entirely and earning these points by using ten different products.
• There is no longer a requirement for no more than 30% of the products to be in the structure and enclosure.
• EPDs that show reduced embodied carbon are given extra credit.