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EPD Source Licence Clearance — Investigation Report

Sub-chat deliverable — Session 5.2 prerequisite Scope: Licence clearance for all EPD programme operators listed in PROJECT.md decision

4 and THIRD_PARTY.md §3, for the specific use case of committing impact values as seed

EPDs in an AGPL-3.0-or-later open-source repository. Date: 2026-07-15

§1 Question under investigation

Can impact values from each EPD programme operator be committed as JSON seed files in backend/app/data/seed_epds/ in this repository (AGPL-3.0-or-later), distributed publicly via GitHub, and served at runtime? For each source, what is the operative licence, what does it permit, and what does it prohibit?

§2 Scope and method

Each programme operator's terms of use, data licence, and/or API licence were reviewed as published at the time of this investigation (2026-07-15). Where terms were not published or were ambiguous, the conservative interpretation (not cleared) is applied.

The operative distinction is between: - Vendoring — committing the impact values as static JSON in the repository (public and redistributable to anyone who clones the repo). - Runtime / cited-only — loading values at runtime from the source's own server or database, with a citation but no static copy committed to the repo.

§3 Verdict table

Source Status Operative licence Vendoring permitted? Runtime/cited only? Notes
ÖKOBAUDAT CLEARED DL-DE-BY-2.0 (Datenlizenz Deutschland — Namensnennung 2.0) Yes — permits redistribution with attribution; no ShareAlike; no ND clause Also permitted German Federal Ministry dataset; DL-DE-BY-2.0 is the German government's standard open-data licence, functionally equivalent to CC BY 4.0 for redistribution. Attribution: "Daten aus der Deutschen Datenbank für ökologische und soziale Bewertung (ÖKOBAUDAT), Bundesministerium für Wohnen, Stadtentwicklung und Bauwesen." Impact values downloaded unmodified; stored in openEPD format (schema transform, not content modification).
openEPD CLEARED Apache-2.0 (schema and library) N/A — openEPD is a format, not a data source N/A openEPD is the internal JSON schema (Building Transparency, Apache-2.0). Licence is for the schema specification and Python library. Clearing openEPD means the act of serialising impact values in openEPD format is permitted — it does not clear any data source.
INIES RESTRICTED Proprietary; free access; redistribution requires written data agreement with INIES/ADEME No without signed agreement Yes — INIES data may be cited (with URL) and loaded at runtime; no static commitment without agreement INIES terms (consulted at inies.fr/utilisation-donnees) specify that redistribution of FDES data in a tool or database requires a formal data agreement. The values 4.87 kg CO₂/kg (FDES 2-152:2020) and similar are usable as citations in methodology documents but may not be committed as seed EPDs without the agreement.
EPD Norge RESTRICTED Proprietary; free access; redistribution requires programme operator consent No without consent Yes — citation permitted EPD Norge terms require contact with the programme operator for data redistribution in third-party tools. Consent not yet obtained. Treat as RESTRICTED until written consent is on file.
IBU (Institut Bauen und Umwelt) RESTRICTED Proprietary; free access via ecoPortal / IBU EPD library; redistribution terms require IBU licence agreement No without signed IBU licence Yes — citation permitted; also reachable via ÖKOBAUDAT copy (see note) IBU EPDs are partially mirrored in ÖKOBAUDAT. Where an IBU-published EPD for a material appears in ÖKOBAUDAT under DL-DE-BY-2.0, the ÖKOBAUDAT version may be committed (citing ÖKOBAUDAT as the source); the IBU original may be cited additionally. Where IBU data is not in ÖKOBAUDAT, it is RESTRICTED.
EPD International BLOCKED Proprietary; data redistribution requires per-EPD licence from the programme owner No — per-EPD clearance needed Possible only with per-EPD written clearance EPD International is an umbrella programme; individual EPDs are owned by the company that commissioned them. No blanket redistribution right exists. Each EPD would require individual clearance. Given project scale and pre-release status, this source is BLOCKED for vendoring until a blanket licence is negotiated.
EPDASA UNKNOWN Terms not published on EPDASA website at time of investigation Cannot determine Cannot determine Marco to contact EPDASA directly. EPDASA is a small programme operator (Australia/New Zealand). No published redistribution policy found. Treat as UNKNOWN until written confirmation is obtained.

§4 Practical implications

4.1 Sole vendorable source at present: ÖKOBAUDAT

Only ÖKOBAUDAT values can be committed to seed_epds/ in the public repository without further negotiation. The public repo builds and runs from ÖKOBAUDAT-derived seeds alone.

4.2 IBU via ÖKOBAUDAT

Where IBU-origin EPDs appear in ÖKOBAUDAT (which mirrors a large fraction of IBU data), the ÖKOBAUDAT copy may be vendored under DL-DE-BY-2.0. The citation must reference ÖKOBAUDAT as the access point; the IBU source may be additionally cited in the justification_text field.

4.3 RESTRICTED sources as an optional runtime layer

INIES, EPD Norge, and IBU-direct are useful as a runtime-only layer: the tool can fetch and display their values if the user is running the tool in an environment where direct API/database access is available. No static commitment to the repo is required or permitted. This keeps the restriction out of the distribution.

4.4 Geographic representativeness caveat (ÖKOBAUDAT)

ÖKOBAUDAT factors are EU-contextualised: they reflect European supply chains, European grid mixes, and European construction practice. Their application to Sub-Saharan Africa contexts introduces geographic representativeness uncertainty. Every seeded ÖKOBAUDAT factor must document its declared geographic scope. Energy-linked life-cycle stages (A4 transport, A5 construction-site, C2 transport-to-waste) are particularly sensitive and require explicit treatment or flagging when African distances and grid mixes diverge significantly from the ÖKOBAUDAT baseline.

This is a standing methodology constraint, not a reason to reject ÖKOBAUDAT data — the pedigree matrix Weidema axis 4 (geographic representativeness, 1–5 scale) captures the uncertainty, and the Monte Carlo propagates it. But it must be documented per seed EPD.

The following items require action before the repository is made public (Phase 3) and before any public release of seed EPD data:

  1. EF 3.1 redistribution terms — The European Commission's Environmental Footprint 3.1 characterisation factors are used in every EPD impact computation. Specific redistribution terms for the factor tables are not clearly published. Legal review required before public release.

  2. ASHRAE CLTD/CLF/SCL table redistribution — The B6 thermal engine uses ASHRAE HoF tables. Table redistribution in the tool requires ASHRAE licence. Flag for legal review before any public release that includes the table data.

  3. ÖKOBAUDAT DL-DE-BY-2.0 attribution compliance — The attribution statement that must accompany every redistribution needs to be embedded in the tool's documentation site, API responses, and exported reports. Legal review to confirm the exact attribution wording satisfies DL-DE-BY-2.0 §3.

  4. INIES data agreement — If INIES FDES values are ever to be vendored (not just cited), a formal data agreement with INIES/ADEME must be signed. This is not a pre-public-release blocker for the repository itself (INIES stays runtime-only), but it becomes a blocker if the team wants to package an INIES-seeded offline installer.

  5. DTU 26.1 redistribution — The thermal-properties technical report from DTU has unknown redistribution terms (THIRD_PARTY.md §4). Values cited with reference in METHODOLOGY.md; redistribution confirmation needed before Phase 3 public docs site publishes those table values verbatim.

  6. EPDASA written confirmation — Required before any EPDASA impact value is committed. Currently UNKNOWN (§3 above).

  1. Immediate (Session 5.2): Record verdict table in THIRD_PARTY.md §3. Lock vendoring policy in PROJECT.md (decision #25). Open legal-review issues.
  2. Before first seed EPD is committed (Session 6+): Select ÖKOBAUDAT as the seed source. Confirm DL-DE-BY-2.0 attribution wording. Write the first seed EPD with full proxy_provenance block documenting geographic scope.
  3. Before public release (Phase 3): Resolve §5 items 1–3. Make a determination on EPDASA (item 6). Negotiate IBU-direct or EPD-Norge licence only if ÖKOBAUDAT does not cover the needed materials.