While some public agencies like Caltrans are integrating embodied carbon metrics into formal procurement standards, some private developers are also responding to market expectations by evaluating material emissions during project planning and design.

In the commercial real estate sector, developers are setting embodied carbon targets independent of policy requirements. Hines, a global real estate development firm, for example, is piloting lifecycle assessments across select building projects and reviewing structural material options to reduce emissions.⁴ These actions are driven by tenant, investor, and stakeholder reporting expectations, not regulation.⁵

EPDs are central to both public and private approaches. Each EPD is based on a Product Category Rule (PCR), a standardized method for calculating and reporting the environmental impacts of a given material type.⁶ Differences across PCRs can affect how emissions data is interpreted in procurement and funding decisions.⁷

Global Context

Governments and infrastructure owners in other countries are taking steps to reduce the embodied carbon of construction materials. In Australia, the Materials & Embodied Carbon Leaders’ Alliance (MECLA), where Deloitte Australia is a founding member, is convening public agencies and private sector actors to coordinate material specification reform. In the UK, the Low Carbon Concrete Group is developing baseline performance thresholds to guide public infrastructure procurement and building codes.

In the European Union, twenty-three member states have implemented or are drafting whole-life carbon reporting and limits for new construction as part of national climate strategies. As examples, France’s RE2020 law introduced embodied carbon thresholds for new buildings beginning in 2022,⁸ Denmark mandates lifecycle emissions assessments for large buildings,⁹ and the Netherlands continues to apply a whole-building carbon cap through its “Milieuprestatie Gebouwen” framework.¹⁰

US Movement

In the United States, the shift toward embodied carbon measurement has emerged more gradually but is now gaining momentum At the federal level, the General Services Administration (GSA) began piloting Buy Clean procurement standards in 2022, requiring EPDs for materials such as steel, concrete, and asphalt in dozens of federal projects.¹¹

At the state level, California continues to lead. In addition to Caltrans’ specification updates, California’s 2024 CALGreen building code requires new commercial buildings over 100,000 square feet to demonstrate at least a 10% reduction in embodied carbon starting in July 2024, reinforcing policy goals under the state’s Buy Clean framework.¹² Colorado, New York, and Oregon are developing similar requirements, though timelines and material scopes vary.

Some private companies have also moved ahead of regulation. Meta, for example, has redesigned elements of its data centers to reduce concrete use and has adopted low-carbon mixes using supplementary cementitious material. In pilot projects, the company reported 20-30% reductions in embodied emissions compared to regional baselines.¹³

As momentum builds, more organizations are beginning to revisit how they incorporate embodied carbon into procurement and design workflows. However, many organizations lack defined processes for tracking embodied carbon, leaving gaps in procurement and design workflows.

Implications for Procurement Strategy

Caltrans’ decision to embed EPDs into procurement reflects a shift from voluntary disclosure to mandatory reporting. The agency requires mix- and plant-specific EPDs, introducing emissions transparency into the contracting process and creating a consistent framework for evaluating material impacts across projects.¹⁴

This approach allows Caltrans to compare emissions data across suppliers and to prioritize lower-emissions products when feasible. It also allows the agency to identify trends in material intensity over time and incorporate those insights into future project planning or standard-setting.

For project owners and contractors, these requirements mean that emissions data is now part of the standard documentation submitted during the bidding process. Suppliers who lack verified EPDs, or cannot demonstrate the ability to lower emissions through material choices, may be less competitive in future procurements.

This evolving procurement landscape raises important strategic considerations for organizations in construction and development. Across both the public and private sector, five common gaps have emerged:

Addressing Market Gaps

Despite recent momentum, much of the US market remains fragmented. PCRs vary in scope and methodology. Not every public agency has the procurement platforms capable of tracking EPDs at-scale, and some regions lack access to lower-carbon material options due to limited local manufacturing or transportation challenges. 

Several states and municipalities are piloting ways to address these issues. Oregon is developing a registry of approved EPDs for commonly used construction materials. Colorado’s Buy Clean law sets maximum emissions thresholds for certain materials and requires reporting from state-funded projects. 

Looking Forward

The Caltrans EPD requirement marks a shift toward using procurement processes to collect and evaluate material-level emissions data. While the specification does not set emissions limits, it establishes a framework that other agencies can consider adapting as emissions reporting becomes more standardized and integrated into funding eligibility criteria.

This requirement also influences how many organizations approach procurement and design decisions. As more agencies adopt similar reporting requirements, emissions data is expected to become a routine part of public and private construction workflows. Organizations that build capacity to assess, verify, and apply this data across their planning and procurement processes may be better positioned to address future requirements and enable long-term environmental performance.

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