A declaration is a disclosure, not a sustainability guarantee: Network Architectural debunks the EPD myth
Environmental Product Declarations (EPDs) are invaluable for transparency, but they don’t automatically make a product sustainable. As Llewellyn Regler explains, EPDs are disclosure tools, not guarantees. This article unpacks the myth, showing why specifiers must look beyond the label to durability, maintenance, lifecycle cost and embodied carbon to achieve genuinely sustainable outcomes.
Charles Perkins Centre, Sydney NSW
The industry’s collective pursuit of increasingly ambitious environmental agendas is often anchored by Environmental Product Declarations (EPDs), which, over the last few years, have become an undeniable cornerstone of sustainable design. Navigating complex certification requirements can be a particularly time-consuming and detail-oriented exercise, and this demanding process has inadvertently solidified the role of EPDs as efficient seals of approval in many specifiers’ minds. We’ve grown accustomed to the idea that if a product has an EPD, then it must be sustainable.
Unfortunately, warns Llewellyn Regler, National Technical Manager at Network Architectural, this common and largely well-intentioned assumption is a critical oversimplification. “The belief that the mere presence of an EPD makes a product sustainable is a myth,” Llewellyn says. “And one that risks undermining the very goals a project might be aiming to achieve.”
The dream of simplicity
According to Llewellyn, this misconception is rooted in a desire for clarity in an increasingly complex field. “EPDs have become synonymous with sustainability in many procurement and certification processes,” he explains. “There’s a misconception that the presence of an EPD means a product meets a certain environmental standard – but in reality, an EPD is a disclosure tool, not a rating system. The growing demand for sustainable design has driven architects and specifiers to look for straightforward ways to demonstrate environmental responsibility, and, unfortunately, that’s often led to a ‘tick-box’ approach.”
Llewellyn adds that this is particularly true for large-scale commercial projects, where decisions must be made and documented with exceptional efficiency. However, by treating EPDs as an administrative formality, the industry risks overlooking the rich, nuanced data they contain, which could potentially lead to suboptimal material choices.
Jarvis Toyota, SA
The indisputable value of an EPD
This is not to say that EPDs don’t hold immense value – they do. And they are an indispensable part of the sustainable specification process. “EPDs provide transparent, standardised data on a product’s environmental impacts throughout its life cycle – most notably in the A1–A3 stages, which cover raw material extraction and manufacturing,” Llewellyn notes. “This makes them valuable for comparing products within the same category and for contributing to lifecycle assessments and certification schemes like Green Star.”
Their superpower is undoubtedly their ability to help assess a product’s embodied carbon, measured as Global Warming Potential (GWP). And as ESG reporting becomes non-negotiable, this data is more vital than ever, making an EPD a crucial starting point. However, Llewellyn points out, that’s precisely what an EPD is: a beginning. To find genuine environmental guarantees, industry professionals must dig deeper. What exactly should they be looking for?
Looking for guarantees, not declarations
In short: context. “An EPD simply presents data,” Llewellyn explains. “It does not interpret that data or provide context. Two vastly different products can both have EPDs, but one may have triple the embodied carbon of another.”
Llewellyn adds that this is a critical distinction, particularly for materials like façade cladding. “For instance, our recent CPD comparing GWP from fossil fuels demonstrates significant differences between three different types of aluminium products,” he adds. “A 3mm solid aluminium panel has a GWP of 61.45 kg CO₂e/m². In comparison, a corrugated core panel sits at 34.10 kg CO₂e/m², while a mineral core panel – like ALPOLIC™ NC/A1 – comes in at just 19.74 kg CO₂e/m².”
This disparity highlights the fact that, although all three products may have EPDs, it’s clear that they’re not as sustainable as one another. Their embodied carbon footprints are worlds apart and streamlining an EPD review to a quick box-ticking exercise would completely miss this crucial performance difference.
But that’s not the only challenge – Llewellyn notes that EPDs often fail to capture other vital long-term sustainability factors. Durability, maintenance requirements, warranty conditions and lifecycle costs are all critical considerations that fall outside the conventional scope of an EPD but have profound environmental and economic consequences over a building’s life.
“A product may have a low impact at the manufacturing stage but require regular repainting, refinishing, or early replacement,” Llewellyn goes on. “And that drives up environmental impact and lifecycle costs.”
Trilogi Apartments, Prahran VIC
Crucial trade-offs and hidden implications
In practice, this means that when architects and designers interpret the sole existence of an EPD as a sustainability guarantee and don’t scrutinise its contents, they can inadvertently specify materials that inflate a project’s environmental footprint. A façade product that appears compliant on paper might come with high embodied carbon, or its warranty might be contingent on a demanding and costly maintenance schedule.
“Take cladding, for example,” Llewellyn says. “Some products may require bi-annual cleaning or treatment to maintain warranty and appearance. Over the lifespan of a commercial building, this leads to increased labour, water, energy use and resource consumption – and adds hidden costs that aren’t reflected in the initial product price or even the EPD.”
This is precisely where a holistic evaluation reveals a product’s true value. “In contrast, ALPOLIC™ NC/A1 not only has one of the lowest embodied carbon footprints in its category but also offers a 20-year full-cover warranty with no requirement for ongoing maintenance,” Llewellyn continues. “Its durability exceeds 50 years, helping reduce waste, lower lifecycle emissions and deliver better long-term value. These are the kinds of insights that can help specifiers make decisions that are genuinely sustainable, not just superficially compliant.”
On large commercial projects, these differences scale up dramatically, affecting everything from environmental performance and building management budgets to tenant satisfaction.
Charles Perkins Centre, Sydney NSW
Reading between lines: A robust assessment framework
It’s abundantly clear that a truly sustainable specification process involves more than checking if an EPD is in place – it’s about adopting a broader perspective and considering the comprehensive environmental and operational impact of materials.
So, we ask Llewellyn which metrics specifiers should pay extra attention to when evaluating EPDs as they compare products to make sure they gain a proper understanding of a product’s sustainability performance. Here’s a handy breakdown:
- GWP: Scrutinise the A1-A3 data to understand the upfront environmental impact.
- Durability and service life: Assess the expected lifespan of the product before it requires replacement.
- Maintenance requirements: Check if there are long-term inputs required to maintain the product’s performance and warranty.
- Warranty conditions: Verify that the warranty is comprehensive and covers materials, labour, and rectification without onerous conditions.
- Fire compliance and safety: Familiarise yourself with this non-negotiable aspect of risk management and occupant safety, especially for façades.
- Lifecycle cost: Consider the total, long-term cost of ownership, including maintenance, repairs and eventual replacement.
- Supply chain and local support: Ensure the product is made responsibly and that local stock, technical support and compliance documentation are readily available.
- End-of-life: Scrutinise whether the product is genuinely recyclable and if it offers a practical pathway for resource recovery in Australia.
Using ALPOLIC™ NC/A1 as an example, Llewellyn explains how these factors can help create a much more comprehensive environmental picture. “ALPOLIC™ NC/A1 is manufactured in Japan by Mitsubishi Chemical Infratec Co., Ltd, a globally respected company known for its ethical production and strict environmental controls,” he offers. “But what makes it especially practical for Australian projects is its local stockholding and support through Network Architectural, which ensures shorter lead times, reduced local freight emissions and direct access to compliance documentation and warranty support.”
Nihon University, Newcastle NSW
Outcomes over checklists: The measured future
Now, Llewellyn is clear that this demand to move beyond a simple EPD box-checking exercise doesn’t just lie with the specifiers. As we continue to shift further away from passive compliance to a more sophisticated whole-of-life approach to sustainability – “a good thing,”he points out – manufacturers and suppliers have a responsibility to provide greater transparency and deeper insights.
“That’s why, at Network Architectural, we take a proactive approach,” Llewellyn explains. “And not only supplying materials that meet stringent compliance and performance standards, but also educating the industry on how to specify better. We offer detailed product guidance, warranty transparency and CPD presentations that unpack lifecycle costs and risks.”
And while EPDs will continue to anchor the sustainable specification process as a vital assessment tool, it’s paramount for industry professionals to integrate this data with critical performance, durability, compliance and ethical sourcing insights.
“Our vision is a construction sector where environmental responsibility is measured not just in checklists but in real-world outcomes – materials that perform for decades, reduce maintenance waste and lower carbon emissions across their full lifecycle,” Llewellyn concludes. “That’s how we can build better buildings – and, ultimately, a better built environment.”
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