The designer opened two EPDs (Environmental Product Declarations) on the same screen. Concrete floors, same thickness, same intended use. On the left, the GWP (fossil) is 78 kg CO₂e per square meter. On the right, 142 kg. He chose the first, included the reference in the specifications, and won the tender. Six months later, an investigation initiated by an unsuccessful bidder found that the two declarations were uncomparable: different PCRs, different energy mixes, and opposing end-of-life scenarios. The more sustainable product on paper was, in reality, indistinguishable from the other. The dispute triggered an administrative proceeding, resulting in the suspension of construction.
This isn't a theoretical scenario. It's statistics . A 2022 study in the Journal of Cleaner Production analyzed hundreds of Environmental Product Declarations in the construction sector: only 0.04% were fully comparable with others in their group, and 89.15% of the possible comparisons were methodologically invalid. The document that should protect against greenwashing is, in everyday use, a more fragile surface than its cover suggests.
From February 2, 2026, this fragile surface becomes the mandatory standard for Italian public procurement.
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Designers can't perform LCAs for manufacturers. What they can do is perform a ninety-second methodological review before adding a product to the specifications. Three questions, in this order.
Who verified the document? Paragraph 2.1.2 of CAM 2025 is explicit: only EPDs verified by an Accredited Certification Body (ACB) are accepted for tender. An EPD validated by a single Individual Verifier, which is quicker and more cost-effective for the manufacturer, does not pass the CAM. CSQA, DNV, Bureau Veritas, TÜV Italia, Kiwa, and ICMQ are among the bodies accredited as ACBs in Italy for the EPD International program. If the document does not include the name of the Accredited Certification Body (ACB) with its accreditation code, the documentation is deemed non-compliant during the CAM verification phase. In the event of a dispute, the administrative liability falls on the contracting authority and, subsequently, on the person drafting the specifications.
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Source: Edilportale