Unverifiable, not high carbon: Why manufacturers lose in specification

Stage 1: Find

No EPD means you're modelled against an industry average

The find stage is where Arcadis builds a baseline carbon model, in this case using One Click LCA, and runs hotspot analysis to see which elements are driving whole life carbon. If your product doesn't have a verified Environmental Product Declaration (EPD), it still gets modelled, just against an industry-average dataset instead of your own figures. That erases any real advantage your product has, good or bad.

This isn't a small gap. One Click LCA's 2026 Carbon Experts Report found that 90% of AEC respondents say they prefer materials with EPDs, and 97% expect demand for verified product data to increase further, yet only 22% of manufacturers currently have EPDs for more than half of their own product portfolio. That gap is exactly the opening: if you're one of the 22%, you're the default comparison, not one option among many.

Stage 2: Decide

Your evidence needs to survive a RAG tracker, not a brochure

Once a baseline exists, Arcadis lists every carbon opportunity on a RAG-rated risk and opportunities tracker, scored by how easily each item can be embedded into the design. On the Cadogan Estates refurbishment programme Arcadis discussed alongside this model, that's why locally sourced recycled structural steel made the list for a car port frame once timber was ruled out by planning constraints, and why local recycled aggregates were a straightforward swap once flagged, while cement replacements (GGBS, fly ash or limestone) needed more evaluation before a decision could be made. The full story is in the "Arcadis turns carbon hotspots into design decisions across two Cadogan buildings".

What gets a green rating on a tracker like this is comparable, quantified, standard-aligned data: a carbon figure benchmarked against a stated baseline, not a marketing claim about being "sustainable." A product description without that comparison doesn't get a red rating. It doesn't get rated at all, because there's nothing to put on the tracker.

Stage 3: Commit

Give the owner something to defend

Every item on the tracker gets an owner, and that person has to justify the decision either way: a tick if the item is embedded, a documented reason if it isn't.

"So the question is not, can we model carbon now? We've moved away from that. And it's actually, can we design, specify, buy, and verify the low carbon answer that we've come to calculate?"
— Emma Maltby, Lead, Whole Life Carbon and Circularity, Arcadis

For a manufacturer, that means the person specifying your product needs a defensible reason for choosing it over a cheaper or more familiar alternative. A specific, sourced carbon delta against a named baseline gives them that. A general claim about your manufacturing process doesn't, because it can't be entered into the justification field on a tracker or defended to a cost manager asking why the budget line moved.

Stage 4: Buy 

This is where sign-off costs you the job, not carbon

The buy stage is where specifications and tender requirements get written, and it's also where Arcadis flagged one of its most common blockers.

"Some innovative materials had issues in getting sign-off. We had to speak to security and fire and all different groups to ensure that we could progress with it."
— Emma Maltby, Lead, Whole Life Carbon and Circularity, Arcadis

This is a genuine opening for manufacturers, not just a compliance hurdle. If your product needs a non-standard sign-off, whether that's fire performance, security, or a structural warranty, supplying that evidence before a specifier asks for it removes the exact friction that gets a low-carbon option dropped for a familiar one under programme pressure.

Stage 5: Verify

Repeat business depends on this stage, not the pitch

Arcadis updates its models at each design stage, including post-construction, to check what was specified against what was actually delivered. If your product's real-world performance holds up against what your EPD claimed, you're the standardised choice on the next project in that portfolio. If it doesn't, you're the reason the next tracker entry gets a red rating.

UK and EU product rules are not the same

This matters more than a footnote for manufacturers selling on both sides of the Channel, because the UK and EU now run genuinely separate regimes, not two names for the same rulebook.

In the EU, the revised Construction Products Regulation (EU) 2024/3110 entered into force in January 2025 and becomes generally applicable from January 2026. It introduces a mandatory Digital Product Passport (DPP) under the related Ecodesign for Sustainable Products Regulation, enhanced CE marking that includes environmental impact data, and requires EPDs to be built into the Declaration of Performance and Conformity itself. It applies to products placed on the EU market, including UK exports into the EU.

In the UK, construction products are still governed by the UK's own 2013 Construction Products Regulations regime and UKCA marking, introduced after Brexit as a domestic replacement rather than a copy of the EU framework. CE marking remains recognised for now, but the UK regime does not currently carry the EU's new Digital Product Passport (DPP) or environmental CE marking requirements. A manufacturer supplying both markets is meeting two distinct sets of obligations, not one regulation under two names.

Layered on top of both is the Carbon Border Adjustment Mechanism, which is pushing verified product-level carbon data further up the priority list for manufacturers exporting into the EU regardless of which side of the CPR split they're on, and Part Z in the UK, which, if enacted, would push UK specifiers to demand the same verified data domestically.

What this means in practice

1. Publish a verified EPD. Without one, you're not being excluded for being high carbon, you're being modelled against an industry average that erases whatever advantage you have.
2. Make your evidence tracker-ready: a quantified carbon figure against a named baseline, not a general sustainability claim.
3. Get sign-off evidence in front of a specifier before they have to ask for it.
4. Know which regulatory regime you're actually being asked to meet. EU CPR and UK CPR are not interchangeable, and treating them as the same thing is a compliance risk in either direction.
   

FAQ

What is an EPD and why does a specifier ask for one?

An Environmental Product Declaration is a standardised, third-party verified disclosure of a product's environmental impact based on a life cycle assessment. UK and EU specifiers increasingly require them to compare products on verified data rather than manufacturer claims. Manufacturers use One Click LCA's EPD Generator to create and verify EPDs to EN 15804 and ISO 21930, then publish them where specifiers search for compliant products.

Is the EU's Construction Products Regulation the same as the UK's?

No. The EU's revised Construction Products Regulation (EU) 2024/3110 applies to products placed on the EU market and introduces a mandatory Digital Product Passport from 2026. Great Britain runs its own separate 2013 Construction Products Regulations regime with UKCA marking, without that passport requirement. One Click LCA's CPR, CBAM and ESPR compliance guide breaks down which obligations apply to which market.

Does my product need to be the lowest-carbon option to be specified?

No. It needs to be defensible against a stated baseline and comparable to alternatives on the tracker. A product with a smaller but verified saving beats an unverified claim of a larger one, because the specifier's owner has to justify the decision with evidence, not intent. One Click LCA's construction LCA database, used by many UK specifiers to benchmark one EPD against another, is where that comparison usually happens before a product reaches a tracker.