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

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 would have introduced concrete as an eligible material, updated the EPD requirements, and added performance-based specification requirements and performance incentives for concrete, but it also did not pass.

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.

AB 2446 (“Embodied carbon emissions: construction materials”) requires 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.

AB 1010 (“Net-Zero Carbon Continuing Education”) requires all licensed architects in the state of California to go through 5 hours of net-zero carbon design continuing education every 2 years (when renewing license).

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.

The Marin Climate Action Plan has a section on consumption-based emissions that addresses embodied carbon by recommending policy and program development that explores low-embodied carbon or carbon-sequestering materials.

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

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

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

San Francisco’s Climate Action Plan includes embodied carbon.

San Francisco has a Construction and Demolition Debris Recovery Law that requires debris and material removed from a project in San Francisco to be recycled or reused. No debris can be transported to or disposed of in a landfill or incinerator or put in a designated trash bin.

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

The Palo Alto Deconstruction & Construction Materials Management Ordinance prohibits demolition for construction projects, instead requiring demolition.

The City of Belvedere's Climate Action Plan has two small pieces that address embodied carbon:

• EE-3: Green Building Reach Code: b) consider adopting low embodied-carbon concrete standards similar to those adopted by the County of Marin (p21)
• SA-2: Carbon Sequestration: a) where appropriate, encourage the use of building materials that store carbon through agency partnership and engagement campaigns (pg32)

The City of Larkspur's Climate Action Plan has two small pieces that address embodied carbon:

• EE-C4: Green Building Reach Code: b) consider adopting low embodied-carbon concrete standards similar to hose adopted by the County of Marin (p28)
• SA-C2: Carbon Sequestration: a) where appropriate, encourage the use of building materials that store carbon through agency partnership and engagement campaigns (pg36)

Livermore’s 2022 Climate Action Plan includes a series of recommendations addressing embodied carbon.

The City of Fairfox's Climate Action Plan has two small pieces that address embodied carbon in Section S-4 Building Materials: 

1. Encourage use of climate-friendly building materials that store more carbon dioxide than is released in their production through agency partnerships and engagement campaigns.
2. Adopt an ordinance requiring the use of low carbon concrete in new construction based on the County’s model ordinance (Ordinance No. 3717, adopted November 2019).

The City of San Anselmo's Climate Action Plan has a small piece that addresses embodied carbon in Section S-4: Building Materials:

a. Encourage use of climate-friendly building materials that store more carbon dioxide than is released in their production through agency partnerships and engagement campaigns.

The City of San Rafael's Climate Action Plan has a small piece that addresses embodied carbon indirectly: "Encourage use of climate-friendly building materials that store more carbon dioxide than is released in their production through agency partnerships and engagement campaigns.”

The Town of Tiburon's Climate Action Plan has a couple of pieces that address embodied carbon:

EE-C4: Green Building Reach Code

1. Adopt a green building ordinance for new and remodeled commercial and residential projects that requires green building methods, materials, and efficiency above the State building and energy codes.
2. Consider adoption of low embodied-carbon concrete standards similar to those adopted by the County.  

EE-C6 Sustainable Building Materials

Study alternatives and draft regulations that require use of Forest Stewardship Council certified material in new constructions, major remodels, and outdoor use and that prohibit use of non-certified old-growth and other materials.

WR-C3: Construction & Demolition Debris and Self-Haul Waste

1. Require all loads of construction & demolition debris and self-haul waste to be processed for recovery of materials as feasible.
2. Investigate creation of an ordinance requiring deconstruction of buildings proposed for demolition or remodeling

The San Leandro Climate Action Plan has a strategy that directly addresses embodied carbon -- CC-3: "Low-carbon building materials."  It directs the City to "work with local, regional, and State partners to expand the awareness of, availability, and cost-effectiveness of low-carbon or carbon-free construction materials."

The City of Emeryville is considering including the use of “Mass Timber,” said to be a more “sustainable” building product, be included in a list of community benefits developers can provide in exchange for additional building height.

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).

HB22-1159 establishes a Waste Diversion And Circular Economy Development Center for Colorado. The purpose of the center is to grow existing markets, create new markets, and provide necessary infrastructure, logistics, and marketing to create a sustainable circular economy for recycled commodities in Colorado.

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

The City of Denver has two amendments to the Denver Building Code related to embodied carbon, one for concrete and one for steel.  Section 901.3.2.1 sets CO2e limit for concrete mixes and requires Type III EPD. Section 901.3.2.2 does the same for structural steel, hollow steel section, steel plate, and concrete reinforcing steel bar products.

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.

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.

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).

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).

Cook County in Illinois has a Demolition Debris Ordinance that encourages reuse and recycling of demolition debris from residential structures.

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.

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.

Executive Order 594, “Decarbonizing and Minimizing Environmental Impacts of State Government,” requires all new construction and substantial renovations funded by the Commonwealth to meet a number of energy and transportation targets including evaluating and implementing strategies to reduce embodied carbon contained in building materials.

The Michigan Healthy Climate Plan indirectly addresses embodied carbon by encouraging the use of materials with a low-carbon footprint (like mass timber) and has a section about driving clean innovation in industry to reduce emissions from energy-intensive industries, such as iron, steel, and cement.

Ann Arbor has a resolution to encourage and accelerate the use of low embodied carbon building materials in construction. The City Administrator will develop criteria to utilize low embodied carbon building materials in its building and infrastructure projects, publish an annual report, and share resources.

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.

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

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.

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.

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.

The Portland Climate Emergency Workplan aims to lower embodied carbon in the built environment by supporting policies that reduce the embodied carbon of building materials and construction through the use of low-carbon alternatives, adaptive reuse, and whole-building life-cycle assessments (LCAs). The Workplan is aiming for net-zero by 2050, and a 50% reduction in current emissions by 2030.

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.

In New Jersey Low Embodied Carbon Concrete Leadership Act (LECCLA), the New Jersey Department of Environmental Protection (DEP) will be charged with establishing embodied carbon baselines for concrete. Producers who submit certified EPDs that fall below this baseline will be awarded a performance-based tax credit of up to 8% of the total cost of the contract.

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 has a green public procurement program called GreenNY.  Currently, it has specifications for low-carbon concrete.

The New York State Climate Action Council included embodied carbon in its Energy Efficiency and Housing Advisory Panel 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.

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 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 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.

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.

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.

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.

The State of Wisconsin's Clean Energy Plan has a section dedicated to exploring low-carbon building materials procurement policies. This mostly consists of researching policies, conducting studies, developing a standardized method for evaluating and reporting embodied carbon emissions, and using EPDs.

The City of Houston has a Building Materials Reuse Warehouse.

Waterfront Toronto Green Building Requirements has a section that specifically addresses embodied carbon.  It requires design teams to do two things: 1) During Schematic Design, design teams should conduct a WBLCA in accordance with CaGBC Zero Carbon Building Standard version 2 methodology; and 2) at Detailed Design, design teams should update the LCA for the proposed building structure.

Toronto’s Green Performance Standard has new voluntary tracking requirements for building construction and landscaping materials, and potential future performance requirements for “embodied emissions” in building materials such as concrete, steel and insulation in small and large buildings.

Douro-Dummer's Sustainable Development Program was launched early 2020 as Canada's first embodied carbon reduction program for building construction. It provides at this time a 40% permit fee rebate on all approved projects that meet the required greenhouse gas reduction targets, or an 80% permit fee rebate combined with net-zero ready construction.

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.

British Columbia's Mass Timber Action Plan mentions a new Low Carbon Building Materials Strategy (coming in 2023) that will guide the province's efforts to reduce embodied carbon.

CleanBC is British Columbia's government plan to lower climate-changing emissions by 40% by 2030.  It was established in 2018.  CleanBC has a Roadmap to 2030, which among many goals, aims to reduce embodied carbon by using more low-carbon building materials, such as mass timber, wood-based insulation, carbon-absorbing concrete, and concrete made with lignin fibres from trees and other plants.  To accomplish this, the government will develop a Low Carbon Building Materials Strategy by 2030 that includes a holistic approach to decarbonizing buildings, initially emphasizing public sector buildings, by 2030.

The City of Vancouver Green Demolition By-Law Update lists a series of recommendations for the City of Vancouver to expand the scope of the existing green demolition program, and establish a deconstruction hub.  The City's Green Demolition By-Laws or Program was originally established in 2014.

Edmonton’s Climate Resilience Policy (Council Policy Number C627) requires all new buildings to be built to an emissions-neutral standard. Embodied carbon analysis is completed for new construction and ideas such as passive design strategies, well-insulated building envelopes and the use of energy-efficient technologies like LED lighting are encouraged. All New Construction shall require Embodied Carbon assessments.

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, Policy Recommendations for Procurement of Low Embodied Energy and Carbon Materials by Federal Agencies, describes approaches that the GSA could adopt to reduce embodied carbon in its construction portfolio, including collection of EPDs during procurement.

Another GSA Advice Letter, Federal Building Decarbonization: Preliminary Recommendations, provides the initial findings and recommendations of the Green Building Advisory Committee on decarbonizing federal buildings, based on the work of its Federal Building Decarbonization Task Group.  Embodied carbon is included in one of its seven key principles.

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 lowering the environmental impacts of concrete and asphalt. These standards would apply to the GSA's construction, modernization, and paving projects across the nation. The concrete standards require EPD submissions and impose emissions limits. The asphalt standards require EPD submissions and the use of environmentally-preferable asphalt.

The Inflation Reduction Act (IRA) of 2022 has multiple pools of funding available for embodied carbon, focusing on low-carbon materials procurement. These include $250M for the EPA for technical assistance related to EPDs, $100M for the EPA to develop a low-carbon material labeling program, and $4.15M for the GSA and FHWA to procure low-carbon materials.

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.

Canada’s Greening Government Strategy is a directive that requires the Canadian government to disclose the amount of embodied carbon in the structural materials of major construction projects by 2022 based on material carbon intensity or a life-cycle analysis. They will reduce embodied carbon of the structural materials of major construction projects by 30%, starting in 2025, using recycled and lower-carbon materials, material efficiency and performance-based design standards. They will also conduct whole building (or asset) life-cycle assessments by 2025 at the latest for major buildings and infrastructure projects.

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.

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.

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).

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 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.

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.

In 2021, the UK Building Regulations had a “Part Z” proposal that would have ensured that embodied carbon was assessed on all projects, but it did not pass.

The UK’s Carbon Emissions (Buildings) Bill would require the whole-life carbon emissions of buildings to be reported, and set limits on embodied carbon emissions in the construction of buildings.  Projects greater than 1000m² or 10 dwellings would need to address and report their whole life carbon from specific dates with limits on embodied carbon emissions being introduced from 2027 based on the data collected in the preceding years.

In 2023, Ireland updated their Climate Action Plan to include the following items related to embodied carbon: 1) establish a focus group to develop actions to decrease embodied carbon in construction materials, 2) decrease embodied carbon for materials produced and used in Ireland by 10% by 2025 and 30% by 2030, 3) actively deliver a series of measures to reduce embodied carbon in construction materials, 4) promote the swapping to lower embodied carbon construction materials wherever possible, 5) and reduce emissions from cement production.

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.