As we move through 2025, the landscape of chemical disclosure in building products has evolved dramatically, driven by regulatory changes, market demands, and the growing recognition that the built environment directly influences occupant health. The convergence of new standards, enhanced transparency requirements, and emerging regulations around per- and polyfluoroalkyl substances (PFAS) is reshaping how manufacturers approach product development and disclosure.
Current State of Chemical Transparency
The momentum for chemical transparency in building products has reached unprecedented levels. Health Product Declarations (HPDs) have become the industry standard for material health reporting, with over 14,000 HPD reports now published. This represents a remarkable achievement in voluntary industry transparency, driven primarily by market demand rather than regulatory mandates.
However, challenges persist. Many building products still contain chemicals of concern, including volatile organic compounds (VOCs), formaldehyde, flame retardants, and PFAS. The complexity of global supply chains makes it difficult for manufacturers to fully understand and disclose all chemical ingredients, particularly when suppliers are reluctant to share proprietary information. The industry continues to grapple with balancing performance requirements with health considerations, as many chemical additives serve important functional purposes in building materials.
The Role of HPDs in Design Practice
Design professionals have increasingly embraced HPDs as essential tools for material selection. Thousands of project teams now use material health disclosures to contribute LEED credits, demonstrating the widespread adoption of these transparency tools. Leading architecture firms, including Perkins+Will, ZGF Architects, and HKS, actively encourage and often require manufacturers to provide HPDs for product specification consideration.
HPDs serve as “ingredient labels” for building products, enabling designers to make informed decisions about material impacts on human health. The standardized format allows for meaningful comparison between products and manufacturers, creating market incentives for healthier formulations. The HPD Open Standard provides a consistent framework for disclosure while giving specifiers the data they need to identify potentially harmful substances and select safer alternatives.
LEED v5: Transparency for Better Materials
The launch of LEED v5 in April 2025 represents a significant evolution in how green building standards approach material health. Unlike previous versions that focused primarily on environmental performance, LEED v5 embraces a more holistic approach with three core impact areas: decarbonization, quality of life, and ecological conservation.
The new LEED v5 Building Product Selection and Procurement credit introduces a comprehensive multi-attribute framework that aligns with industry initiatives like the Common Materials Framework and the AIA Materials Pledge. This credit encourages the selection of products that have been optimized across multiple impact areas, including climate health, human health, ecosystem health, social health and equity, and circular economy principles.
LEED v5’s emphasis on transparency creates powerful market incentives for manufacturers to develop comprehensive product documentation. The system now rewards not just the availability of ingredient information, but also optimization efforts that reduce environmental and health impacts. This shift encourages manufacturers to move beyond simple disclosure toward active reformulation and improvement of their products.
The strategic partnership between the Health Product Declaration Collaborative (HPDC) and the U.S. Green Building Council (USGBC) has focused on ensuring smooth integration of HPD information to support the new LEED v5 requirements. This collaboration has streamlined the process for project teams to identify and specify products that meet both transparency and optimization criteria.
LEED Compliant HPDs: Essential for Market Access
For manufacturers, developing LEED-compliant HPDs has become essential for market access. The requirements are specific: HPDs must demonstrate chemical inventory disclosure to at least 1,000 parts per million (ppm), be complete according to the HPD Open Standard, and be published in the HPD Public Repository. Many leading firms now give preference to manufacturers with third-party verified HPDs, which receive enhanced value under LEED v4.1 and v5.
The process of developing LEED-compliant HPDs has become more sophisticated, with manufacturers increasingly working with approved third-party preparers like Elixir Enviromental. These experts help navigate supply chain complexities, ensure compliance with the HPD Open Standard, and provide the technical expertise needed for hazard screening.
Supply chain transparency remains one of the biggest challenges in HPD development. Manufacturers often discover suppliers they were unaware of during the HPD development process, sometimes extending to suppliers in complex global manufacturing networks. Success requires strong relationships with suppliers and sometimes involves non-disclosure agreements with third-party assessors to protect proprietary information while enabling transparency.
PFAS Disclosure: A New Regulatory Frontier
The regulation of PFAS represents one of the most significant developments in chemical disclosure requirements. These “forever chemicals” are present in numerous building materials, including paints, coatings, sealers, carpets, and metal finishes. PFAS provide valuable performance characteristics such as water and stain resistance, but their persistence in the environment and potential health impacts have prompted extensive regulatory action.
Federal regulations now require comprehensive PFAS reporting under the Toxic Substances Control Act (TSCA). The EPA’s Section 8(a)(7) rule, finalized in 2024, requires manufacturers and importers to report on PFAS manufactured or imported since 2011. Following delays due to system development challenges, reporting deadlines have been extended to October 2026 for most manufacturers, with small businesses having until April 2027.
State-level PFAS regulations are advancing rapidly, with at least 37 states introducing PFAS legislation in 2025. These laws focus on four primary areas: consumer products, firefighting materials, biosolids and pesticides, and water systems. Several states, including California, Maine, and Minnesota, have implemented or will soon implement comprehensive PFAS disclosure and restriction requirements for building products.
For building product manufacturers, PFAS disclosure requirements create both challenges and opportunities. Manufacturers may now disclose PFAS in their building product HPDs. This added transparency can help increase product specification opportunities.
Industry Response and Future Outlook
The building industry’s response to these evolving requirements has been largely positive, with many manufacturers viewing transparency as a competitive advantage rather than a burden. Companies are investing in supply chain mapping, chemical assessment capabilities, and reformulation efforts to meet growing transparency demands while maintaining product performance.
As we progress through 2025, the state of chemicals in building products reflects both significant progress and ongoing challenges. The widespread adoption of HPDs, the evolution of LEED v5, and emerging PFAS regulations are creating a more transparent and health-conscious building industry. Success will require continued collaboration between manufacturers, designers, regulators, and health advocates to ensure that the built environment supports both human health and environmental sustainability.