A Niscai perspective on what an 85% EPD expectation actually demands from a supplier.

An EPD requirement doesn't test whether a supplier believes in sustainability. It tests whether their evidence was built to survive being asked for twice.

That distinction is about to matter a great deal more. CF25, the Department for Education's new construction framework, live since early 2026, no longer treats EPDs as a nice-to-have. Its Employer's Requirements set a rising bar: the whole-life carbon assessment on a school must be backed by product-specific EPDs across an escalating share of the building by mass (50% by RIBA Stage 3, 75% by Stage 4, 85% by handover) 

At a joint FIS and Recolight webinar this month, Willmott Dixon's James Upstill-Goddard put the headline plainly: the Department for Education now expects 85% of all materials and products in a school, by mass, to have an Environmental Product Declaration available. He called it a huge undertaking and said it's clearly where the industry is heading. That's a contractor describing what's being asked of him on live projects, not a line from a brochure.

Read as a target, 85% sounds like a compliance exercise. Read as a filter, it's something else entirely: a mechanism that separates suppliers who can produce evidence on demand from suppliers who could only ever produce it once.

Two suppliers, one lot

Picture two suppliers bidding into the same DfE lot. Both say their products are low carbon. Both have a sustainability page. Only one of them can, if asked mid-project, produce a current, product-specific, third-party verified EPD for the exact item going into that school.

On the tender document, they look identical. At the point someone actually asks, they don't. The gap between them was never ambition or intent. It was always whether the evidence was built to be retrieved on demand, or assembled once, for one purpose, and then filed away.

That gap didn't matter much when nobody was checking. It matters a great deal when 85% of a school's materials by mass are expected to clear that bar.

What turns a target into a check

An EPD requirement only bites if something forces it to be revisited. Orms' Rachel Hoolahan, on the same panel, described how her practice now runs every project on a carbon budget: a base budget set at the outset, then a developing budget the team works down from there, tracked the way a project's finances are tracked, on projects of any size. That's the mechanism. Once carbon has a budget the way cost has a budget, it gets monitored the way cost gets monitored: stage by stage, checked against actuals, not signed off once at the start and forgotten.

A figure quietly stated in a sustainability page survives a one-time read. It does not survive a budget line, where someone is coming back to check it against actuals at every stage of delivery.

That's what a budget does to a claim. It stops being read once, at tender stage, and starts being tested every time someone downstream needs to know if the project is still on track.

Why this isn't really about DfE

CF25 is one framework, but the mechanism behind it isn't specific to school buildings. An EPD expectation pegged to mass, a carbon budget tracked like project finance, product-level data expected to hold up mid-project: this is what happens whenever a buyer moves sustainability from something scored once at tender to something checked throughout delivery. Once that shift happens in one sector, it tends not to reverse, and it tends not to stay contained to one sector either.

The suppliers this catches out were never the ones without a sustainability story. They're the ones whose story holds up at the pitch, but not when someone asks them to prove it mid-project.

That's the gap Niscai exists to close: making product-level environmental data something a supplier can retrieve and stand behind whenever it's asked for, not just something they can say at the point of sale.

Carbon reporting requirements from the DfE's Construction Framework 2025 (CF25) Employer's Requirements: Technical Manual, Section 0 (Environmental Design), Table 3, published 11 February 2026. 

Comments from James Upstill-Goddard (Willmott Dixon) and Rachel Hoolahan (Orms), reported by BDC Magazine, 15 July 2026, from a joint FIS and Recolight webinar on embodied carbon and EPDs.