Resource Library:

CLF Embodied Carbon Policy Toolkit

The Carbon Leadership Forum has created a Carbon Policy Toolkit — an array of resources to support the crafting of policies to radically reduce embodied carbon. For questions regarding embodied carbon policy toolkits in your region, email us or join a Carbon Leadership Forum Regional Hub to connect with other interested professionals in your city. 

Scroll down to find additional resources from the Carbon Leadership Forum:

Policy Primer Educational Series

Policy is an essential step towards creating the scale of action required to rapidly reduce embodied carbon in construction. The policy primer series (toolkit) below begins with an introduction to procurement policies, also known as Buy Clean. Keep checking back to see additional primers on other carbon policy areas.

Several key forms of embodied carbon policies to look out for in 2021 include:

  • Procurement policies (like Buy Clean and material-specific variations)
  • Climate Action Plans
  • Building codes
  • City zoning, land use, and building regulations and incentives, including building and material reuse policies
  • Executive orders addressing embodied carbon of building and industrial sector emissions

Current Embodied Carbon Policy

Embodied carbon policies are spreading rapidly across the United States and the world. Click on the map markers below to learn more about existing and proposed policies.  For more information about the individual policies, see the links for each policy below the map.

Hint: Change the dropdowns below the map to filter the policy list or see more than 5 policies at a time. Click on a pin to see details.

National Policy     State or Provincial Policy      Local Policy​

Jurisdiction Categories Policy name and description
State of California
Approved, State or Province

The Buy Clean California Act was introduced and passed by the state legislature in 2017.  This was the first case of Buy Clean legislation in the United States.

In 2021, SB-778 and AB-1369 were amendments introduced to fill in gaps in the Buy Clean California Act. AB-1369 would have introduced finish materials and shifted the requirement for EPDs to be product-specific instead of facility-specific, but it did not pass.  SB-778 introduces concrete as an eligible material, updates the EPD requirements, and adds performance-based specification requirements and performance incentives for concrete; it is on hold until 2022.

The Caltrans EPD Implementation Project collects EPDs for each eligible material in a Caltrans project in order to quantify total global warming potential (GWP).

SB 596 (“Greenhouse gases: cement sector: net-zero emissions strategy”) requires the state board to develop a comprehensive strategy for the state’s cement sector to achieve net-zero emissions of greenhouse gases of cement used within the state as soon as possible.

In 2022, AB 2446 (“Embodied carbon emissions: construction materials”) was proposed, which would require the CA Energy Resources Conservation and Development Commission (in consultation with the California Air Resources Board) to design a framework for measuring and reducing the carbon intensity of construction and materials to achieve an 80% net reduction in new construction by 2045, with interim goals of 20% below 2020 levels by 2030 and 40% below 2020 levels by 2035.

SB 260 (“Climate Corporate Accountability Act”) would require companies doing business in CA that have greater than $1 billion in revenue to report their scope 1, 2, and 3 emissions (third party verified).

SB 1297 (“Low-embodied carbon building materials: carbon sequestration”) would require the State Energy Resources Conservation and Development Commission to develop a plan to advance low-carbon materials and methods in building and construction projects.

AB 2446 (“Embodied carbon emissions: construction materials”) would require the CA Energy Resources Conservation and Development Commission (in consultation with the California Air Resources Board) to design a framework for measuring and reducing the carbon intensity of construction and materials to achieve an 80% net reduction in new construction by 2045, with interim goals of 20% below 2020 levels by 2030 and 40% below 2020 levels by 2035.

Marin County, CA
Approved, Local

The Marin County Low Carbon Concrete Code contains a set of requirements that reduce the greenhouse gas emissions of concrete while still maintaining the strength and durability of concrete.

City of Albany, CA
Approved, Local

Albany’s 2019 Climate Action and Adaptation Plan includes embodied carbon.

City of Dublin, CA
Approved, Local

Dublin’s Climate Action Plan 2030 and Beyond (CAP 2030) includes embodied carbon.

City of Los Angeles, CA
Approved, Local

Los Angeles's Green New Deal Sustainable City "pLAn" incorporates embodied carbon.  Los Angeles is a signatory city to C40's Clean Construction Declaration.

City of San Francisco, CA
Approved, Local

San Francisco’s Climate Action Plan includes embodied carbon.

City of Oakland, CA
Approved, Local

Oakland’s 2030 Equitable Climate Action Plan (ECAP) includes embodied carbon.

State of Colorado
Approved, State or Province

The bill “Global Warming Potential For Public Project Materials,” also known as “Buy Clean Colorado,” was introduced to the Colorado State Legislature in 2020 but did not pass into law.  This bill was reintroduced and passed into law in 2021 (HB21-1303).

State of Connecticut
Proposed, State or Province

HB 5444 ("An Act Concerning the Carbon Content of Concrete Used in State Projects") was introduced in 2021 to encourage the use of low-carbon construction materials, but it did not pass.

State of Minnesota
Approved, State or Province

A Buy Clean Minnesota bill was introduced to the Minnesota State Legislature in 2019 but did not pass into law.

In 2021, an amendment to HF278 was added, commissioning an environmental impacts study to explore the feasibility of Buy Clean-like legislation for the State of Minnesota

The Minnesota B3 Program provides tools and guidelines for new buildings or renovations to meet sustainability goals for site, water, energy, indoor environment, materials, and waste.  The B3 Guidelines are required on all projects that receive general obligation bond funding from the State of Minnesota.

State of Hawaii
Proposed, State or Province

The State of Hawaii tabled a bill in 2019 that would have required all state building construction to use carbon dioxide-mineralized concrete (HB1282 HD1).

City of Honolulu, HI
Approved, Local

The City of Honolulu passed a resolution requesting the city administration to consider using carbon dioxide-mineralized concrete for all future city infrastructure projects utilizing concrete (RES 18-283).

State of Maryland
Proposed, State or Province

HB 806 was introduced in 2022, and includes a section titled the “Buy Clean Maryland Act,” which requires the submission of EPDs and establishes maximum GWP values for eligible materials on eligible projects.

SB 0528: Climate Solutions Now Act of 2022 requires the Maryland Green Building Council (MGBC) to evaluate the use of EPDs, performance incentives, expedited product evaluation of low-carbon concrete, and maximum GWP limits for concrete used in State-funded projects. MGBC must report its findings and recommendations to the Governor and the General Assembly by December 1, 2022.

State of Massachusetts
Proposed, State or Province

In 2021, the State of Massachusetts proposed “An act relative to green building materials” (H.4182) that sets limits on maximum acceptable greenhouse gas emissions.  This bill is currently under consideration.

City of Newton, MA
Approved, Local

The City of Newton’s Green Building Principles include guidelines for selecting low embodied carbon materials.

City of Boston, MA
Approved, Local

The Boston Mass Timber Accelerator aims to build and scale the use of mass timber practices throughout Boston as a key element in a net zero carbon economy.

City of Somerville, MA
Approved, Local

The Somerville Zoning Ordinance prioritizes "Net Zero Ready Buildings" as one of its evaluation criteria.

City of Eugene, OR
Approved, Local

The City of Eugene Community Climate Action Plan focuses on concrete and asphalt, requires the use of supplementary cementitious materials (SCMs) for concrete, and will explore the future use of EPDs and low-carbon concrete mixes.

State of Oregon
Approved, Proposed, State or Province

The bill “Relating to procurements of certain materials at lowest carbon dioxide cost; declaring an emergency,” also known as Buy Clean Oregon, was introduced to the Oregon State Legislature in 2017 but did not pass into law.

In 2022, HB 4139 was introduced and passed, which requires the Oregon Department of Transportation to establish a program to reduce GHG associated with concrete, asphalt pavement, and steel products used on DOT projects by 2025.  This is a transportation-flavored version of Buy Clean.

The Oregon Concrete EPD Program provides a free tool to create concrete EPDs and cost reimbursement incentives for Oregon concrete producers. This program is a partnership between the Oregon Concrete & Aggregate Producers Association (OCAPA) and the Oregon Department of Environmental Quality (ODEQ).

In 2021, HB 2688 was introduced; it requires the Oregon Department of Transportation to establish a pilot program to assess how their procurement activities affect carbon dioxide emissions.


City of Portland, OR
Approved, Local

The City of Portland Low-Carbon Concrete Purchasing Program requires the submission of product-specific concrete EPDs for City construction projects and phases in a maximum acceptable global warming potential (GWP) limit.

The City of Portland also has residential deconstruction requirements and preferential purchasing for Oregon-made and recycled goods.

State of New Jersey
Proposed, State or Province

Assembly Bill 5223 establishes State purchasing preference for low embodied carbon concrete; provides corporate business tax credits for costs of conducting environmental product declaration analysis.  This bill was introduced in 2021.

Assembly Bill S3091 (passed 2021) requires developers to offer unit concrete products that utilize carbon footprint-reducing technology as an option in new construction; establishes tax incentives, and State and local purchasing preferences, for unit concrete products that utilize carbon footprint-reducing technology.

State of New York
Approved, State or Province

The New York State Low Embodied Carbon Concrete Leadership Act (LECCLA) requires all of New York State’s authorities and agencies to include climate impact in their selection criteria for concrete procurement, encouraging the use of low-carbon concrete.  This bill was passed in 2021.

Port Authority of NY & NJ Clean Construction Program addresses embodied carbon through EPD requirements, waste diversion, low-carbon concrete, pilot projects, and LEED and Envision-equivalent standards for environmentally-friendly infrastructure design.

The State’s Executive Order 4 (passed in 2008) established a Green Public Procurement program called GreenNY.

The New York State Climate Action Council included embodied carbon in its Advisory Panel/Working Group Recommendations.

In 2022, “The Climate Forward Concrete Leadership Act” (A09042), was proposed, which would require the New York State Office of General Services (in consultation with the state interagency committee) to modify the low-carbon concrete green procurement specs for New York State every 3 years; publish maximum GWP limits for concrete;  establish performance-based specs for use in buildings/horizontal infrastructure by 2023; and establish low-carbon procurement rules for state projects using both a prescriptive and performance-based approach.

Village of Hastings-on-Hudson, NY
Approved, Local

The Hastings-on-Hudson Low Embodied Carbon Concrete Resolution (2020) commits the local government to promoting the use of low embodied carbon concrete products in building and infrastructure projects.

Port Authority of New York/New Jersey
Approved, Local

Port Authority of NY & NJ Clean Construction Program addresses embodied carbon through EPD requirements, waste diversion, low-carbon concrete, pilot projects, and LEED and Envision-equivalent standards for environmentally-friendly infrastructure design.

State of Washington
Approved, Proposed, State or Province

The first Buy Clean Washington bill was introduced in Washington State in 2018. While the bill did not pass, it resulted in funding the five state pilot projects and the Buy Clean Washington Study performed by the CLF, published in 2019.

An updated Buy Clean and Buy Fair bill was proposed for the 2021 legislative session but did not pass.

Two Buy Clean Buy Fair bills were proposed for the 2022 legislative session (a House version and a Senate version), but they did not pass.

In 2018, Governor Jay Inslee signed Executive Order 18-01, “State Efficiency and Environmental Performance.” The order requires consideration of net embodied carbon on state-owned new facility construction.

City of Seattle, WA
Approved, Local

The City of Seattle has several green building permit incentives that center around clean electric energy, water, and resource conservation with a focus on human health. Projects can gain additional height, floor area, or a faster building permit in exchange for meeting specific green building goals and certification.

Seattle’s Green Building Standard incentive program requires green building rating systems such as LEED and the Living Building Challenge that include embodied carbon requirements.

King County, WA
Approved, Local

The King County 2020 Strategic Climate Action Plan includes several strategies related to low-carbon procurement starting with concrete and expanding to wood, steel, and asphalt.

City of Austin, TX
Approved, Local

The City of Austin Climate Equity Action Plan addresses embodied carbon by incentivizing lower-carbon materials, whole building life cycle design, educating stakeholders on materials best practices, and partnering with local materials markets to decarbonize high-impact materials.

The City of Austin Green Building Program includes a rating system and guidebooks that involve credits/points for whole building life cycle assessment (WBLCA) and embodied carbon reductions.

City of Houston, TX
Approved, Local

The City of Houston has a Building Materials Reuse Warehouse.

City of Toronto, ON
Approved, Local

Waterfront Toronto Green Building Requirements has a requirement that new buildings must use more sustainable building materials.  Options include using 50% recycled metal in steel and rebar, low-carbon concrete (with 25% Supplementary Cementitious Materials), or timber products certified by the Forest Stewardship Council.

City of Vancouver, BC
Approved, Local

In Vancouver’s Green Building Rezoning Requirements, in order to receive a rezoning permit, design teams must commit to pursuing either Passive House or the City’s 10 Low Emission Building Requirements, one of which includes reporting the building’s embodied carbon through a WBLCA.

City of Phoenix, AZ
Approved, Local

Phoenix’s Climate Action Plan includes standards to reduce embodied carbon.

United States of America
Approved, National, Proposed

FHWA Order 4460.3A Green Procurement Planning establishes a policy for implementing a green purchasing program for the Federal Highway Administration (FHWA).

FHWA Sustainable Pavements Program provides resources for transportation agencies to reduce embodied carbon, such as the Pavement LCA Tool and a webinar series on asphalt sustainability.

The CLEAN Future Act (proposed) would establish federal “Buy Clean” standards using federal funds. These standards would promote the procurement of building materials and products that were manufactured through low-GHG intensity processes. The bill would also establish a National Environmental Product Declaration (EPD) database to help verify the embodied carbon of materials and products acquired with federal funds

The GSA Advice Letter describes approaches that the GSA could adopt to reduce embodied carbon in its construction portfolio, including collection of EPDs during procurement.

One of the requirements of Biden’s executive order, Catalyzing America’s Clean Energy Economy Through Federal Sustainability, is to require "Net-zero emissions from federal procurement no later than 2050, including a Buy Clean policy to promote use of construction materials with lower embodied emissions."  It also includes a goal for "A net-zero emissions building portfolio by 2045, including a 50 percent emissions reduction by 2032."

In 2022, the GSA issued new standards for concrete and asphalt used in nationwide GSA construction, modernization, and paving projects, specifically for concrete and asphalt.

District of Columbia (Washington D.C.)
Approved, Local

The D.C. Green Building Fund Grant Program provides grants that help the District of Columbia enact climate policy.  The 2022 period includes language on embodied carbon.

Approved, National

The Royal Decree on environmental messages sets the minimum requirements for environmental displays on construction products and for the registration of environmental product declarations in the federal database.

Approved, National

In Bæredygtighedsklassen ("The Sustainability Class"), project teams must complete an LCA assessing the building's life cycle climate impact when applying for a building permit and when completing construction. Limits on the building’s climate impact are being developed with the goal of establishing limits in 2023.

Sustainability in Construction and Civil Works (Public Project Requirements) are a set of requirements that include: 1) performing LCAs of at least two elements in a building, 2) using crushed builders’ rubble as a substitute for base gravel, 3) analyzing which building elements can be reused before demolition or renovation, 4) recycling uncontaminated materials.

Approved, National, Proposed

Finland’s Act on public procurement and concession contracts 1397/2016 outline a set of Green Public Procurement Requirements that include 1) calculating the GHG emissions of materials, 2) selecting options that are both low-cost and carbon-optimal, 3) requiring at least 10% of materials to be renewable or recycled, and 4) performing an audit of reusable components before demolition.

Finland is also developing legislation for low-carbon construction to aid in reaching carbon neutrality by 2035, including normative carbon limits for different building types before 2025. Finland’s Ministry of the Environment has developed an assessment method and will develop a generic emissions database (link).

Approved, National

France has a mandate that requires all new public buildings to be built from at least 50% timber or other natural materials.  In addition to wood, the mandate can be fulfilled by bio-based materials made from matter derived from living organisms such as hemp and straw.

The Bâtiment à Énergie Positive & Réduction Carbone / Énergie Positive et Réduction Carbone (E+C-) is a pilot program incentivizing builders and developers to achieve energy and carbon performance-based targets for the whole life cycle of buildings. This pilot program will become mandatory in 2022, through the ‘RE2020’ policy included in the Energy Transition for Green Growth law. Projects will no longer receive incentives for participation and will be expected to meet life cycle carbon limits.

The Netherlands
Approved, National

The Netherlands has a building decree (circa 2013) that requires all new residential and office buildings in excess of 100 m2 to have their embodied carbon emissions calculated and reported (called an ‘MPG’). As of January 1, 2018, a maximum limit value of 1.0 applies to the MPG. On 1 July 2021, the environmental performance for new homes (not for offices) tightened from 1.0 to 0.8. The aim is to gradually tighten the requirement and to halve it by 2030 at the latest.

The Dutch Sustainable Public Procurement (SPP) Policy expresses a preference for bidders who can prove that their operations lead to significant CO2 reductions and a preference for circular economy principles.  The Dutch government also developed a Sustainable Public Procurement (SPP) Tool [Maatschappelijk verantwoord inkopen (MVI)] and the DuboCalc software to calculate environmental life cycle costs.

Approved, National

Minergie-Eco is a construction label in Switzerland for new or renovated buildings. Embodied carbon calculations are one of its requirements.  The program provides a free Excel tool for calculating embodied energy in early design stages.  This requirement is voluntary but required by the City of Zurich.

New Zealand

In 2022, New Zealand published a Whole-of-Life Embodied Carbon Assessment Technical Methodology for assessing the embodied carbon of new buildings after several rounds of public comment. The aim of this methodology (currently only voluntary) is to support the consistency of embodied carbon assessments of buildings in New Zealand, enabling early adopters to incorporate the methodology in their own processes.