Label Program for Low Embodied Carbon Construction Materials
- What is Embodied Carbon?
- Inflation Reduction Act
- Grant Program
- Tools, Resources and Funding Opportunities
In support of Inflation Reduction Act Section 60116, EPA is working to identify construction materials and products with substantially lower levels of embodied carbon. In the draft approach for the label program, EPA proposes to standardize and improve the quality of data used in Environmental Product Declarations (EPDs), which disclose key environmental impacts of a product’s lifecycle. It also proposes a process to use data from EPDs and other sources to set thresholds for the amount of embodied carbon a product can have related to similar products to qualify for the label. The final phase of the draft approach is for the program to certify materials and products and to create a central registry of certified products.
EPA expects that the label’s end users will be those engaged in federal procurement of lower embodied carbon construction materials and products, including:
- specifiers for federal agencies making direct purchases of construction and materials and products for federally funded building and transportation infrastructure projects,
- construction project staff,
- construction contractors,
- those participating in the development and implementation of Buy Clean programs,
- manufacturers of lower embodied carbon construction materials and products who would like their products to be eligible for use in federally funded construction projects,
- federal entities that set criteria for programs that provide funding for materials and products procured as part of transportation infrastructure and/or building construction and
- architects, engineers and others involved in federal construction who may use lower embodied carbon construction materials and products in federally funded projects, rating systems and construction planning tools.
Using EPA’s label program for low embodied carbon construction materials will help agencies meet the direction in Executive Order 14057 to achieve net zero emissions from procurement by 2050. Additionally, the Inflation Reduction Act of 2022 provided the General Services Administration and Federal Highway Administration with over $4 billion to procure substantially lower embodied carbon construction materials based on determinations made by EPA. The Agency intends for this label program to ultimately replace EPA’s Interim Determination. The Inflation Reduction Act also provides for the Federal Emergency Management Agency and Department of Housing & Urban Development to procure and use low embodied carbon construction materials.
Draft Label Program Approach Notice of Availability
On Feb. 15, 2024, EPA announced that it had issued a Notice of Availability to seek public input on the Agency’s Draft Label Program Approach (pdf) . This draft program approach was informed by public input received in response to a Request for Information released last year which helped inform the prioritization of work and key design elements of EPA’s initiatives to address embodied carbon of construction materials.
These material categories were selected based on:
- their high embodied carbon levels,
- the availability of environmental product declarations for some of these materials and
- being the vast majority of construction materials and products purchased with federal funds.
EPA is currently prioritizing emissions associated with raw material supply, transportation to the manufacturing facility and manufacturing (A1-A3 or “cradle to gate” emissions in a life cycle assessment) due to the relatively high share of total life cycle greenhouse gas emissions attributed to these stages for most materials, including concrete, steel, glass and asphalt, and lack of data availability in EPDs for other product life cycle stages. EPA expects to consider other life cycle stages in the future.
Label Program and EPA’s Recommendations of Specifications, Standards and Ecolabels
EPA's Recommendations of Specifications, Standards and Ecolabels (“Recommendations”), also managed by EPA’s Environmentally Preferable Purchasing Program, was launched in 2015 in response to direction to use private sector standards in federal procurement (NTTAA, OMB A-119) and to help federal purchasers identify and procure environmentally preferable products and services (Executive Order 14057).
The Recommendations currently cover some construction materials, such as carpet and paint, but not the initial materials proposed by EPA’s label program for low embodied carbon construction materials. EPA is working to add a filter to the Recommendations webpage to allow users to better understand how the recommended standards and ecolabels already require or incentivize addressing climate change.
Recommendations of Specifications, Standards & Ecolabels |
Label Program for Low Embodied Carbon Construction Materials & Products | |
---|---|---|
Materials and Products Covered |
Construction categories currently covered by the Recommendations: Adhesives; Carpet; Ceiling Tiles: Acoustical Fiberboard, Gypsum Panels and Wallboard; Flooring: Tile, Resilient and Other Non-carpet; Insulation; Interior Latex Paint; Other Miscellaneous Building Finishes |
Construction materials/products purchased with federal funding with initial focus on concrete/cement, asphalt, steel, and flat glass |
Environmental Attributes Covered | Multiple environmental and human health attributes over the life of the product, including greenhouse gas emissions in some instances | Lower embodied greenhouse gas emissions with an initial focus on the production stag |
Potential Inclusion of Additional Materials
The proposed approach for implementing the label program outlines how other materials can be included over time. EPA’s proposed initial focus on the material categories of steel construction products, asphalt mixtures, concrete mixtures, and flat glass is consistent with the 2022 Interim Determination and the Federal Buy Clean Initiative.
EPA would consider the inclusion of other materials in the label program if manufacturers of those materials take the actions necessary to move through the phases of the label program, including:
- developing and/or updating the relevant product category rule to meet the upcoming EPA Product Category Rule Criteria and
- generating a sufficient number of EPDs to ensure there is representative data upon which to create thresholds.
Like other material categories, salvaged and reused materials will be considered depending on input from the public, adequate EPA resources and advancement of life cycle assessments, product category rules and environmental product declarations that address these materials. The Low Embodied Carbon Construction Materials Program released a Notice of Funding Opportunity for EPD Assistance grants in September 2023. The grant program encouraged applications for projects related to embodied carbon and reuse, with example projects including exploration of reused material EPDs and PCRs. Applications were due Jan. 16, 2024, and EPA is in the process of reviewing proposals. EPA is hopeful that the grant program builds capacity in the salvage and reuse sector (and others) to compete in the growing Buy Clean/low carbon construction marketplace.
If/when a material meets these requirements and as resources allow, EPA may consider expanding the label program to cover additional materials and products with significant potential to reduce their embodied carbon.
The label program focuses on the embodied carbon of construction materials, rather than toxics and other concerns, because that is the purpose of the funding provided by Congress via the Inflation Reduction Act of 2022 section 60116. The agency may consider addressing other key environmental impacts as the label program evolves, if appropriate, depending on data quality and the availability of resources.
However, EPA’s embodied carbon work under this program is just one aspect of a much broader set of actions being taken within the federal government to improve sustainability in the U.S. construction sector. Programs across the federal government are implementing and supporting broad approaches to sustainable building practices, including renovating and reusing existing building stock, creating whole-project carbon budgets, optimizing material volumes and encouraging the use of salvaged materials through deconstruction and reuse.
Tips for Companies Seeking Certification Under EPA's Label Program
Develop EPDs for the materials and products that your company manufactures. Environmental product declarations will be used to evaluate materials and products for inclusion in the label program. In the near future, EPA and its grantees will provide no-cost technical assistance to help manufacturers develop EPDs. If you would like to receive additional information on how to receive this free assistance, please sign up for the EPA Environmentally Purchasing Program’s (EPP’s) mailing list. Learn more about technical assistance tools and resources for developing EPDs.
Reduce the embodied carbon in the materials and products your company manufactures. Through producing an EPD, manufacturers will be able to identify opportunities to reduce embodied carbon. Manufacturers who don’t yet have an EPD developed can identify embodied carbon reduction options by reviewing the life cycle assessment used in the product category rule for their material or product.
Some common ways to reduce the embodied carbon of construction materials and products, while maintaining performance standards, include:
- Manage energy and invest in energy-efficient upgrades: EPA’s ENERGY STAR Industrial Program offers manufacturers technical support to help them reduce the embodied carbon of their materials and products.
- Join ENERGY STAR’s Industrial Assistance Network to receive training, tools, and individual coaching. Email EnergyNetwork@energystar.gov to learn more
- Reduce your energy intensity and participate in the ENERGY STAR Challenge for Industry to receive EPA recognition.
- Use the ENERGY STAR Energy Performance Indicators (for available sectors) to understand the energy efficiency of your plants. Plants that earn 75 out of 100 or higher are eligible for ENERGY STAR plant certification.
- Use ENERGY STAR resources to find ways to reduce energy and carbon by conducting an Energy Treasure Hunt.
- Power your facilities, when possible, with electricity from renewable sources. Consult EPA’s Green Power Partnership to learn how to reduce emissions associated with conventional electricity use while supporting the domestic development of clean energy resources.
- Improve the efficiency of your freight transportation: Participate in EPA’s SmartWay program to better benchmark, report and reduce Scope 1 and Scope 3 freight emissions.
- Shift to lower-impact input materials or material mixes, including shifting towards circular manufacturing processes such as incorporating what would have been waste materials into new products.
- Invest in lower carbon fuels.
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Webinar: Developing a Label Program for Low Embodied Carbon Construction Materials
On Feb. 27, 2024, EPA hosted a webinar to solicit feedback on the draft approach for developing a label program for construction materials and products with low embodied greenhouse gas emissions as authorized by the 2022 Inflation Reduction Act. The webinar also posed key questions.
Slides for Feb. 2024 webinar on draft label program approach. (pdf) .
Recording of Feb. 2024 webinar on draft label program approach.
Draft Product Category Rule Criteria
On March 5, EPA published a Notice of Availability to seek public input on draft Criteria for Product Category Rules (PCRs) to support the Label Program for Low Embodied Carbon Construction Materials through a 30-day comment period. The PCR criteria was informed by public input received in response to a Request for Information released last year which helped inform the prioritization of work and key design elements of EPA’s initiatives to address embodied carbon of construction materials.
Read more about Product Category Rules.
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Webinar: EPA’s Efforts to Improve Product Category Rules for Environmental Product Declarations
On March 21, 2024, from 1 to 2 p.m., EDT, EPA hosted a webinar to educate stakeholders on the PCR criteria and how it is expected to improve Environmental Product Declarations.
Slides for March 2024 webinar on draft Product Category Rule criteria (pdf)
Recording of the March 5 webinar on draft Product Category Rule criteria.