HPD Preparation for Manufacturers: An Ingredient Disclosure Checklist

Manufacturers already gathering data for an EPD may have a useful starting point for an HPD, but the two information requests should not be treated as identical. Factory energy records help an environmental model; they do not establish a complete substance inventory. Plan HPD preparation as its own workstream.

Define the product before requesting ingredients

Decide which formulation and product variants the declaration is intended to cover. Ask the technical team to explain which components are supplied ready-made and which are mixed on site or at the factory. Keep a controlled product identifier so the declaration can be matched to the item actually purchased by a project.

Understand the reporting threshold

The HPD reporting threshold determines the level of substance disclosure. HPDC notes that 100 ppm is a more detailed threshold than 1,000 ppm. As a unit conversion, these correspond to 0.01% and 0.1% by mass; the applicable standard determines how thresholds are applied in the inventory. Consult the current technical instructions.

Do not choose a threshold simply because it produces fewer unanswered questions. Establish the project requirement first, then document the supplier information needed to meet it. Where information remains unknown or proprietary, use the applicable reporting rules rather than inventing a composition.

Make supplier questions specific

A practical supplier request should identify the component, version, requested disclosure basis and person responsible for responding. Ask for supporting information appropriate to the current HPD instructions. A generic safety data sheet may be useful supporting evidence but should not be assumed to contain every substance needed for the disclosure. Record the source and date of each response.

Use the HPD workflow, not a carbon-model export

HPD Builder is a dedicated tool for preparing these disclosures. The current standard and supporting instructions should govern the work. One Click LCA can serve the parallel LCA/EPD project, but an EPD output is not a substitute for an HPD. See the HPD Builder and published Open Standard versions.

Review unresolved information before publication

Our suggested internal review separates confirmed data, supplier responses awaiting clarification and unresolved gaps. Ask whether the product names, component relationships and disclosure statements agree across the document. Have any specialist interpretations checked by someone qualified to make them. Do not market completion of a disclosure as proof that a product is free from all health concerns.

Coordinate the HPD and EPD schedules

Use one document register but separate technical approvals. This allows procurement teams to see both workstreams without assuming that they share the same evidence or verification route. If a formulation changes, assess the implications for each document rather than updating only the carbon model. This article is preparation guidance, not an offer of independent HPD verification or health certification.

Related guidance

• Comparing EPDs in One Click LCA: Avoiding Misleading Carbon Rankings
• One Click LCA Building Assessments: From BIM Quantities to Reviewable Results
• EN 15978 life-cycle modules explained

Reviewed September 12, 2026. General technical guidance, not a certification or verification decision. Confirm current programme rules, standard editions and software entitlements for your project. DOE Modellers is not represented here as a programme operator or independent verifier.