What do you declare?

Environmental Product Declarations may change the way roofing projects are specified


An Environmental Product Declaration (EPD®) is a disclosure document that provides quantitative environmental impact data based on products' life cycles. The reported data can be used in the material selection process for construction projects.

Although it currently is unusual for roofing project specifications to require roofing products with EPDs, using roofing products with EPDs is becoming more common in the roofing industry. It's a good idea to become familiar with how EPDs are developed and how they may be required.

How are EPDs developed?

EPDs are a type of ecolabel, which is a document that discloses or reports environmental or sustainability data for products, including construction materials, to assist consumers with selecting products. Ecolabels are developed based on the International Standards Organization (ISO) 14000 series of environmental standards. ISO 14020, "Environmental Labels and Declarations—General Principles," establishes three main types of ecolabels:

  • Type I: ISO 14024, "Environmental Labels and Declarations—Type 1 Environmental Labelling—Principles and Procedures"
    • Multicriteria label describing attributes or characteristics for the performance and use of a product
    • Reviewed by a third party
    • Not based on a life cycle assessment (LCA)
  • Type II: ISO 14021, "Environmental Labels and Declarations—Self-declared Environmental Claims (Type II Environmental Labelling)"
    • Requirements for a manufacturer to self-declare environmental impact information
    • Not based on an LCA
  • Type III: ISO 14025, "Environmental Labels and Declarations—Type III Environmental Declarations—Principles and Procedures."
    • Environmental impact data based on an LCA
    • Reviewed by a third party

EPDs result from a Type III ecolabel development process according to ISO 14025. As part of EPD development, ISO 14025 requires an LCA be conducted to determine the environmental impact data to be reported in EPD documents. LCAs evaluate how products are made (raw materials acquisition, manufacturing and transportation), used (installation, use and maintenance) and disposed (disposal, reuse or recycling). For EPDs, LCAs are conducted according to ISO 14040, "Environmental management—Life Cycle Assessment—Principles and Framework," and ISO 14044, "Environmental management—Life Cycle Assessment—Requirements and Guidelines."

An important aspect of EPD development programs is the process requires a program operator. Program operators are independent companies, trade associations, public authorities, agencies or independent scientific bodies that serve as impartial administrators. Some common program operators are ASTM International, ICC Evaluation Service, NSF International and Underwriters Laboratories Inc. (UL).

The process also requires the use of Product Category Rules (PCRs) to ensure EPDs for similar construction products use the same development rules so EPD data can be compared among similar products. Construction-product-related PCRs are developed according to ISO 21930, "Building Construction—Sustainability in Building Construction—Environmental Declaration of Building Products."

If existing, relevant PCRs exist, they can be used or adapted by program operators. If a PCR doesn't exist, program operators develop new PCRs by working with product manufacturers, trade groups and other interested stakeholders. The process requires a panel of experts to review and verify new PCRs conform to ISO 21930. Also, new or adapted PCRs must include a process where interested parties have an opportunity to comment, and all comments must be addressed.

Following is a typical process product manufacturers may use to develop an EPD:

  1. Engage a program operator to facilitate the process per ISO 14025.
  2. Identify a PCR document to be followed per ISO 21930 to establish the rules for EPD development. If no PCR exists for the product type in question, a separate process to develop or adapt an appropriate PCR must be undertaken before an EPD can be developed.
  3. Conduct an LCA for the product following ISO 14040.
  4. Create the EPD based on the results of the LCA per ISO 14025.
  5. Publish the EPD and report environmental impact values. The reported values are based on a common sample size determined by PCRs. Impact categories are based on ISO Standard 21930. The PCR used to create an EPD determines impact categories that are reported for a particular EPD.

Not all EPDs will report all the values noted in the sidebar. The PCR that governs a particular EPD development will determine which of the possible impact categories will be reported. Also, two kinds of EPDs are possible:

  • Industry-wide EPD: Information from many similar products are used to create a generic EPD for a product category. This EPD type establishes average impact category values for the category.
  • Product-specific EPD: Information from a specific single product is used to create the EPD. The impact category values from this EPD type can be compared with the values in an industry-wide EPD or with other product-specific EPDs that were developed using the same PCR.

The roofing industry's progress

Currently, there are few EPDs available for common U.S. roofing products such as membranes or shingles though three PCRs have been published. The available roofing product-related PCRs follow:

  • Asphalt Shingles, Built-up Asphalt Membrane Roofing and Modified Bituminous Membrane Roofing
    • Listed product group: Asphalt shingles applied over underlayment and low-slope roof assemblies consisting of various combinations of factory-produced asphalt-saturated/coated base sheets, ply sheets and cap sheets with specified viscous asphalt coatings, adhesives and surfacings.
    • Program operator: ASTM International
    • Developed by: Asphalt Roofing Manufacturers Association and representatives of its member companies: Atlas Roofing Corp., Atlanta; Building Products of Canada Corp., LaSalle, Quebec City, Canada; CertainTeed Corp. (Saint-Gobain), Valley Forge, Pa.; GAF, Wayne, N.J.; Johns Manville, Denver; Malarkey Roofing Products, Portland, Ore.; Owens Corning, Toledo, Ohio; and TAMKO Building Products Inc., Joplin, Mo.
    • Version adoption: July 2014
    • Validity period: July 2014-June 2019
  • Single Ply Roofing Membranes
    • Listed product group: Thermoplastic or thermoset membrane of compounded synthetic materials manufactured in a factory for use in roofing and waterproofing
    • Program operator: ASTM International
    • Developed by: SPRI Inc. in collaboration with ASTM International
    • Version adoption: November 2012
    • Validity period: November 2012-September 2018
  • Insulated Metal Panels & Metal Composite Panels, and Metal Cladding: Roof and Wall Panels
    • Listed product group: Insulated metal panels, metal composite panels and metal cladding: roof and wall panels
    • Program operator: UL Environment
    • Developed by: American Iron and Steel Institute; Alcoa Architectural Products, Eastman, Ga.; ATAS International Inc., Allentown, Pa.; Centria, Pittsburgh; Fabral, Lancaster, Pa.; Kingspan Group, County Cavan, Ireland; McElroy Metal Inc., Bossier City, La.; Metal Sales Manufacturing Corp., Louisville, Ky.; ALPOLIC Materials/Mitsubishi Plastics Composites America Inc., Chesapeake, Va.; and Petersen Aluminum Corp., Elk Grove Village, Ill.
    • Version adoption: Oct. 9, 2012
    • Validity period: Oct. 9, 2012-Oct. 9, 2017

Although there may be other roofing product EPDs in development based on these PCRs, the following were published at press time:

  • White, single-ply polyester-reinforced PVC roof membrane with finished 40-, 48- and 60-mil thicknesses
    • EPD type: Type III, industry wide
    • Owner of industry-wide EPD: Chemical Fabrics and Film Association
    • PCR used: Single Ply Roofing Membranes
    • EPD program operator: ASTM International
    • Issue date: Aug. 15, 2014
    • Validity period: Aug. 15, 2014-Aug. 15, 2019
    • Declaration No.: EPD-009
  • EverGuard® TPO
    • EPD type: Type III, product specific
    • Manufacturer: GAF
    • PCR used: Single Ply Roofing Membranes, ASTM International (program operator)
    • EPD program operator: NSF International
    • Issue date: Dec. 18, 2013
    • Validity period: Dec. 18, 2013-Dec. 18, 2018
    • Declaration No.: EPD10005
  • EverGuard Extreme™ TPO
    • EPD Type: Type III, product specific
    • Manufacturer: GAF
    • PCR used: Single Ply Roofing Membranes, ASTM International (program operator)
    • EPD program operator: NSF International
    • Issue date: Dec. 18, 2013
    • Validity period: Dec. 18, 2013-Dec. 18, 2018
    • Declaration No.: EPD10006

Are EPD-products required?

Although it currently is unusual for roofing project specifications to require products with EPDs, the use of products with EPDs is becoming more common to comply with environmental credit-rating systems such as the U.S. Green Building Council's (USGBC's) LEED® Version 4 (LEED v4) and The 2030 Challenge by Architecture 2030.

Administered by USGBC, LEED is a points-based certification program commonly used for public sector or high-profile commercial projects to highlight construction and operation methods that are focused on sustainability. In June 2013, LEED v4 was approved. It officially was launched by USGBC in November 2013 and will be required for all new LEED projects registered on or after June 1, 2015.

Developing LEED v4 was controversial and included six rounds of public comments before its approval. Considered a significant overhaul of the rating system, LEED v4 includes a reworking of material and resource credits to incorporate disclosure of environmental and health effects, including the submission of EPDs for specified construction products; the submission of EPDs was not part of previous LEED versions.

Although not all LEED projects will pursue credits that require the submission of EPDs, projects using LEED v4 may contain requirements for roofing-related products to have published EPDs. When bidding on or preparing submittal packages for LEED v4 projects, review project specifications and LEED checklists carefully for requirements of EPDs for roofing-related products and confirm with specified product manufacturers that EPDs for desired products are available. If EPDs are not available for products required to have EPDs, consult with project design teams or owners' representatives before submitting bids or material submittals.

The 2030 Challenge is a voluntary initiative administered by Architecture 2030, a nonprofit organization founded in 2002 by architect Edward Mazria. Current adopters of The 2030 Challenge include individuals, architectural and engineering firms, and material and product manufacturers. Individuals and companies taking part in The 2030 Challenge are asked to pursue a commitment to reducing fossil fuel and energy consumption in new construction and major retrofit projects.

To encourage design professionals to specify products and manufacturers to produce products in line with The 2030 Challenge goals, The 2030 Challenge for Products was developed. To comply, products must meet a maximum carbon-equivalent footprint of 30 percent below the product category average.

Design professionals adopting The 2030 Challenge for Products also are asked to "pledge to request third-party expert verified Life Cycle Assessment (LCA) and, where possible, Environmental Product Declaration (EPD) results from product manufacturers and specify low-carbon building products that meet the Challenge targets."

Adopting product manufacturers are asked to "pledge to conduct and publish third-party expert verified LCAs and, where possible, EPDs for your products and commit to reducing the carbon-equivalent footprint of your products to meet the Challenge targets."

At press time, hundreds of adopters of The 2030 Challenge, as well as local, state and federal legislative resolutions that reference The 2030 Challenge, were listed on Architecture 2030s website, www.architecture2030.org. There are far fewer companies that have specifically adopted The 2030 Challenge for Products.

When reviewing bidding documents or preparing submittal packages, examine project specifications carefully to see whether EPDs are required as part of The 2030 Challenge requirements. If so, at this time, it may be difficult or impossible to show compliance for roofing-related products.

According to The 2030 Challenge staff, there is not an established method for evaluating products from organizations that have not adopted The 2030 Challenge or for products from industries without an industry-wide EPD.

At press time, only one industry-wide EPD for a roof covering product used in the U.S. has been developed, so the documentation does not yet exist for most commonly used roofing products to determine whether a roof system would comply with The 2030 Challenge. If you find yourself in this situation, consult with project design teams or owners' representatives before submitting bids or material submittals.

The future of roofing EPDs

Currently, most roofing-related material manufacturers seem to be taking a wait-and-see approach to EPD development. Reasons why a roofing material manufacturer may be delaying EPD development include:

  • Lack of available PCRs: Before an EPD can be developed, there must be a relevant PCR to establish the framework for producing comparable EPDs. PCRs can be costly to produce and time-consuming to develop because they typically involve participation from several industry stakeholders.
  • EPD development is expensive: It has been reported that a typical EPD development process for a single product can cost between $25,000 and $100,000 depending on a product's complexity. Much of the cost is to conduct an LCA per ISO guidelines. Although there are some economies of scale where a manufacturer could conduct simultaneous LCAs for similar products, the costs for EPD developments are significant for roof system manufacturers, especially manufacturers with multiple product lines or a range of roof system types (or both).
  • Uncertainty of EPDs becoming widely used: Although EPDs arguably are the most established type of material content declaration document, there remain uncertainties for wide-scale adoption of EPDs. There are concerns within many industries that an investment in EPD development ultimately will be wasted if the relative popularity of EPDs diminishes in favor of some other reporting method type.
  • Lack of EPD awareness. Some within the roofing industry are unaware of EPDs and their potential importance for compliance.

Working together

Despite the challenges of EPD development, some roof covering manufacturers indicate they are moving forward with developing EPDs using published PCRs, but the process may take some time because of the complexities of completing LCAs needed for EPD development. Others have reported a desire to create additional industry-wide EPDs for roofing products.

As roofing product-related EPDs are released, Professional Roofing will share the news.

Jason Wilen, AIA, CDT, RRO, is an NRCA director of technical services.




Commonly reported impact categories for construction-product-related EPDs

  • Global warming potential in kilograms (kg) of equivalent carbon dioxide (kg CO2 equiv)
  • Acidification potential in kilograms of equivalent sulfur dioxide (SO2 equiv)
  • Eutrophication potential in kilograms of equivalent nitrogen (kg N equiv)
  • Smog creation potential in kilograms of equivalent ozone (kg O3 equiv)
  • Ozone depletion potential in kilograms of equivalent chlorofluorocarbon-11 (kg CFC-11 equiv)
  • Total primary energy consumption
    • Nonrenewable fossil in mega joules (MJ)
    • Nonrenewable nuclear in MJ
    • Renewable (solar, wind, hydroelectric and geothermal) in MJ
    • Renewable (biomass) in MJ
  • Material resources consumption
    • Nonrenewable material resources in kg
    • Renewable material resources in kg
    • Net fresh water (inputs minus outputs) in liters (l)
  • Nonhazardous waste generated in kg
  • Hazardous waste generated in kg



Did you know?

NRCA has published LEED v4: Roofing-related Provisions, a guide that explains the roofing-related provisions of the most recognized sustainable building rating system, the LEED® Rating System, Version 4 (LEED v4). The guide explains background information, descriptions of possible roofing-related credits and prerequisites for rating systems for the Building Design and Construction and Building Operations and Maintenance categories. Also included is a listing of typical LEED-related submittals and an accounting of the roofing-related provisions that have changed in LEED v4 versus previous LEED editions.

For more information, visit shop.nrca.net or contact NRCA's Customer Service Department at (866) ASK-NRCA (275-6722) or info@nrca.net.

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