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Full Disclosure: The Drive Toward Building Material Transparency

Scott  Alan

My first LEED project was in the year 2000, and it was difficult to find basic information on materials (like recycled content and VOC content) to support the LEED materials and indoor environmental quality credits. Leading manufacturers were just beginning to create LEED compliance fact sheets and supporting documentation. Some first-generation LEED product data was reasonably well aligned with credit requirements, while others were lacking, but it was all quite basic and focused on single-attribute claims. Savvy product manufacturers embraced LEED and their product information improved over time. 

Fast forward to today, where we see the adoption of more robust product requirements in LEED v4, the Living Building Challenge (LBC) and the WELL Building Standard (WELL). Building product manufacturers and the designers who specify their products are now catching up with these new standards. The focus is on material transparency and a deeper understanding of a given product’s impacts on the environment and human health. 

The following is a summary of four of the most common product certifications and disclosures. The summary includes what they cover, how products are assessed, and how they relate to the various rating systems.

Environmental Product Declarations (EPDs)

The International EPD System supports manufacturers in creating life cycle assessments (LCAs) to communicate the environmental performance of their products, based on the International Organization for Standardization (ISO) 14025 standard. The standardized format of an EPD summarizes the environmental impacts associated with a product's raw material extraction, energy use, chemical makeup, waste generation and emissions to air, soil and water. An EPD can be unique to a single product by a specific manufacturer, or it can cover a generic material (e.g., concrete or steel) with an industry-wide or sector EPD. 

For LEED v4 MR Credit Building Product Disclosure, an EPD for any material that is used in the project can contribute toward the 20 products required to earn the credit. However, product-specific EDPs contribute fully toward this threshold, while industry-wide EPDs count as half a product. Products with a publicly available LCA (per ISO 14044) but no EPD, count for only one-fourth of a product.

Manufacturers create EPDs by conducting a life cycle inventory and assessment, which is then validated by an approved third-party. The process starts with finding or creating Product Category Rules (PCRs) for the type of product being assessed, which outline the product-type specific parameters for an LCA. Using the PCRs, the manufacturer (or their consultant) then develops the LCA based on ISO 14040 and 14044 standards. The results of the LCA are reported in a prescribed format and then confirmed by a recognized verifier or approved certification body. It is then ready for registration and publication by the International EDP System. While EPDs represent a significant advance in product transparency (even with the prescribed reporting requirements) it can still be difficult to draw comparisons between similar products.

Health Product Declarations (HPDs)

While EPDs focus on environmental impacts, HPDs catalog product ingredient details and assess them for likely hazards based on leading research in human health implications of the chemicals and compounds they contain. Created by the Health Product Declaration Collaborative (HPDC), HPDs provide a standard reporting format to enable transparent disclosure of building product content and associated health information. 

HPDs are prepared by manufacturers (or their consultants) using the HPDC’s prescribed format and are stored in a searchable public repository after following the quality control protocol. Products with HPDs that report constituents down to 1,000 ppm can contribute to earning the LEED v4 MR Credit Building Product Disclosure and Optimization - Material Ingredients, and WELL Features 26 (Enhanced Material Safety) and 97 (Material Transparency). If constituents are reported down to 100 ppm, they can also satisfy key requirement of the Declare program and contribute to Living Building Challenge Imperative 10 – Red List.

The HPDC recently completed a pilot of its third-party verification program and is now moving forward with full implementation, giving manufacturers and specifiers greater confidence in the information provided. HPDC-approved third-party verifiers will conduct independent quality assurance reviews to confirm the validity and source of data.


The International Living Future Institute (ILFI) administers the LBC rating system, which includes a prohibition of certain materials (the Red List) containing constituents that pollute the environment, bio-accumulate in the food chain or pose a health risk to factory or construction workers. To support compliant manufacturers and assist specifiers, the ILFI established the Declare label to help identify chemical Red List-free materials for LBC projects. 

Declare is a transparency-driven product ingredient label and database where manufacturers self-disclose the ingredients in their products, much like nutrition labels on food products. Labeled products can also contributes to LEED v4 credits if they disclose ingredients, even if they are not Red List-free. Manufacturers can apply for a label with a simple online submission, disclosing information such-as the location of manufacturer, the life-expectancy of the product, expected product end-of-life (e.g., take-back, recycle, landfill), and most importantly an ingredients list. 

The ILFI allows manufacturers to request a proprietary ingredients exception for ingredients that make up less than 1 percent for the product. Products are added to the publicly-available Declare database after ILFI review and acceptance of applications. Optional third-party verification is available from ILFI-approved verifiers. 

Cradle to Cradle (C2C)

Created in 2002 by McDonough Braungart Design Chemistry and administered by Cradle to Cradle Products Innovation Institute, the Cradle to Cradle (C2C) Certified Product Standard is designed to encourage manufacturers to rethink the way they make products. The certification assesses and certifies products across five quality categories: material health, material reutilization, renewable energy and carbon management, water stewardship, and social fairness. It gives a certification score (basic, bronze, silver, gold, or platinum) for each category and awards certification based on the lowest category score. 

The Institute trains and certifies independent assessors, who are contracted by manufacturers to review products. The assessor submits product reports to the Institute, which in turn reviews and certifies the products. In addition to the initial third-party assessment, manufacturers must submit a demonstration of their continuous improvement processes every two years. C2C is focused on product optimization rather than reporting, and does not disclose the ingredient list to the public. 

The evolution of building product disclosures and certifications has been positive overall for manufacturers, designers, construction workers, building occupants and the environment. Manufacturers benefit from the differentiation, trust and brand loyalty built through transparency, as well as the opportunity to drive sustainable product innovation. Likewise, the ease of accessing and comparing data allows specifiers to select products with confidence that desired health and sustainability goals will be met. The availability and consistency of reported data still presents challenges, and manufacturers and advocates for transparency are working to improve and harmonize assessment, reporting and certification processes to be more user friendly for all. We have come a long way, and I am excited to see the next advances as we drive toward material transparency.

Alan Scott, FAIA, LEED Fellow, LEED AP BD+C, O+M, WELL AP, CEM, is an architect with 30 years of experience in sustainable building design. He is a senior associate with WSP in Portland, Ore. To learn more, visit and follow Scott on Twitter @alanscott_faia.