Why an Iraqi manufacturer would publish an EPD
Not because the law says so. It does not. The reason is that the people buying your product are working to certification systems and tender rules that count declarations, and today they cannot count yours.
Iraq has no EPD programme and no rule requiring one
There is no Iraqi EPD programme, no Iraqi Life Cycle Assessment regulation and no Iraqi or Kurdistan Region green public procurement requirement. We looked, and we found none. Nobody should sell you a declaration on the basis of an Iraqi compliance deadline, because there is no Iraqi compliance deadline.
The Kurdistan Regional Government's published sustainability programmes cover afforestation and electricity supply — the Green Belt Project and the Runaki programme — not product environmental declarations.
We also could not find a single Environmental Product Declaration registered to an Iraqi manufacturer in the International EPD System's public library. We put that as a search result rather than as a fact about the world, because that library's search is rendered in the browser and other programme databases were not each enumerated exhaustively.
So the driver is export access and certification, not regulation. Everything below follows from that.
LEED and BREEAM projects need supplier declarations
Green building certification is where product declarations turn into orders. A project team chasing a materials credit has to assemble declarations from its actual suppliers, and the arithmetic is explicit about what each kind is worth.
| What the supplier provides | How much it counts toward the credit |
|---|---|
| Product-specific Type III Environmental Product Declaration | 1 whole product |
| Industry-wide or generic Type III Environmental Product Declaration | 0.5 product |
| Critically reviewed ISO 14044 life cycle assessment, not a declaration | 0.25 product |
Option 1 asks for at least 20 different permanently installed products from at least five manufacturers. The credit is worth up to two points, and the exemplary-performance threshold is 40 products. A product-specific declaration is therefore worth exactly twice a generic industry-average one to the project team deciding what to specify.
BREEAM International New Construction Mat 01, life cycle impacts, awards a credit where at least five specified and installed products are covered by verified declarations, with the exemplary level at ten.
Credit rules: LEED v4 BD+C MRc2 reference and BREEAM International NC Mat 01.
And those projects exist in Iraq now
Iraq has three LEED-certified buildings to date, and a substantial registered pipeline: a large Sulaymaniyah cluster registered in April 2026 — four residential towers of roughly 55,000–63,000 m² each, a 77,832 m² mall, a 45,323 m² Core & Shell office tower and a 48,451 m² hotel tower with a performance centre — plus Downtown Slemani under LEED for Communities, registered February 2026. Earlier registrations include the University Presidency Building in Erbil, Al Qasim Green University and Al Yarmouk Park Community Hall in Mosul.
Every one of those projects will be looking for MRc2-eligible products. Our sister site leediraq.com documents that market in detail, including the American University of Kurdistan Male Residence Facility in Duhok, the first LEED Gold-certified new-construction building in Iraq.
Gulf and Turkish buyers, and international tenders
Outside Iraq, a declaration is increasingly a condition of being on the bid list rather than a differentiator on it.
GCC procurement
Saudi and UAE projects working to LEED, BREEAM or local green building systems ask suppliers for declarations in tender documents. Our authored record already includes a UAE manufacturer and a Saudi one.
Turkish supply chains
Turkish contractors and material buyers work with declarations routinely; seven of the ten manufacturers whose declarations we authored are Turkish.
International tenders
Donor-funded and multinational tenders list environmental documentation as a submission requirement, and a registered declaration answers it with a number instead of a statement of intent.
CBAM: what it is, and what an EPD does not do for it
The EU's Carbon Border Adjustment Mechanism ran a transitional phase from 2023 to 2025, and its definitive regime began on 1 January 2026. It covers cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Under the definitive regime importers must be authorised, must report, and must buy and surrender CBAM certificates for embedded emissions at a price tied to EU ETS auctions.
An Environmental Product Declaration does not satisfy, cover or discharge CBAM. CBAM requires a specific verified embedded-emissions calculation under its own methodology, with its own verification. Different instrument, different method, different verifier. Anyone telling you an EPD handles your CBAM obligation is wrong.
What is true is narrower and more useful: the primary production data behind a CBAM calculation and the primary data behind an LCA are largely the same data — material inputs, fuel and electricity by product line, process emissions, production volumes. A manufacturer who has already built that data set is not starting from zero.
And the limit on the CBAM argument for Iraq
We are not going to overstate this. EU imports from Iraq were €12.7 billion in 2025, of which 99.7% was fuel and mining products. Iron, steel, aluminium, cement and fertiliser do not appear as import categories at all. Iraqi cement today goes to Syria, not to Rotterdam. CBAM is therefore not a live compliance crisis for Iraqi building-materials manufacturers, and the Omnibus simplification under Regulation (EU) 2025/2083 excuses importers below a 50 t/yr de minimis threshold entirely.
The defensible position is forward-looking: if EU market access is part of your five-year plan, the product-level emissions data set is the thing to build now, and it serves your declarations, your customer questionnaires and your carbon reporting at the same time.
Sources: European Commission on CBAM and DG TRADE, EU–Iraq trade.
An Iraqi manufacturer can register a declaration today
This is the part most people get wrong. There is no Iraqi programme to wait for, because you do not need one: declarations are registered by international programme operators, and at least one of them already covers Iraq by name.
The International EPD System runs a MENA regional office, CLC EPD MENA, whose published service area lists Iraq alongside Saudi Arabia, the United Arab Emirates, Kuwait, Oman, Qatar, Jordan, Morocco, Bahrain and Lebanon. The other five operators we have worked with — IBU, EPD-Global, SCS Global Services, Global GreenTag and UL Environment — register internationally: between them they have registered declarations we authored for manufacturers in Türkiye, the United Arab Emirates, Saudi Arabia and Australia.
Start with the market, not the paperwork
Tell us which buyers are asking and what they are asking for. That determines the programme operator, the Product Category Rules and the declared unit — in that order.