Finally, with only 14 months to go before 2025, CO2nstruct Zero have said that they will be able to provide data on their 2025 target for 40% of product portfolios to have EPDs in Quarter 1 of 2024.

In the meantime, we still have no idea whether a “product portfolio” means a manufacturer’s portfolio of products, and whether they could meet this target if they have just one product specific EPD for one of their products, or whether they need to have specific or average product EPD covering their whole portfolio?

When I looked at EPD for UK produced products at the start of 2023 as part of my PhD research, I found around 600 EPD from 110 UK companies and 5 UK trade associations. The Construction Products Association in the UK states their industry comprises nearly 24,000 companies covering construction product manufacturers and suppliers. Assuming this would mean 24,000 product portfolios, then performance against this metric at the start of 2023 would be 0.46%. To meet the target by 2025, CO2nstruct Zero would need 9,500 more companies to develop at least one EPD.

So my guess is that “small businesses” will not be included initially. BEIS estimate that 1.6% of VAT registered UK businesses had 50 or more employees (they classify businesses with less than 50 employees as small), so this would quickly bring us down to around 384 eligible product portfolios (if the construction product sector is similar to the UK business sector in general), and with 110 UK companies already having at least one EPD, already 4.5% would already have met the requirement (though I suspect a few of those 110 companies would be classified as small businesses).

Even if 400 medium and large UK construction product manufacturers had at least one EPD, we would still be a considerable way from allowing every client in the built environment sector to have available carbon data for construction products to make informed lower carbon choices, if these EPD didn’t cover the range of products in their portfolios, and the range of construction products that are used in construction.

It seems clear that the original metric and target was not developed with any real understanding of what it might mean. I look forward to the publication of the next CO2nstruct Zero Performance Framework Quarterly Report to find out exactly how they have defined the metric and how they think the industry has performed.