Nov 5, 2020

Looking Ahead to Embodied Carbon Policy Action in 2021

As the tools and expertise available to measure and reduce embodied carbon have expanded, the urgency has shifted necessarily away from basic understanding of the importance of embodied carbon to taking bold steps towards meaningful action and reductions.

The embodied carbon footprint of a building includes all carbon emissions connected with the manufacture, transport, and installation of construction materials.

Policy is an essential step towards creating the scale of action required to rapidly reduce embodied carbon in construction. Policy at the local, state, and federal levels is uniquely positioned to:

  • Create a market demand for low carbon products through government procurement policy
  • Encourage standardization of embodied carbon data collection and reporting
  • Encourage  investment into (or provide direct funding for) the research and development of technologies needed for industrial decarbonization
  • Extend education and action on embodied carbon beyond industry or regional leaders

Reducing embodied carbon in buildings also depends on the decarbonization of the industrial sector, which requires new strategies focused on research and technology to address the unique challenges of carbon-intensive manufacturing processes. Electrification, fuel switching, and energy efficiency – all key solutions for addressing emissions in cities and the building sector as a whole – are not enough, because they do not reduce the direct release of carbon during manufacturing.   The level of investment required in infrastructure changes is significant and requires a large signal from the entire construction industry.

Policies can support increased investment into research and technology for carbon capture and other solutions for direct emissions during manufacturing as well as sending that signal to create a market demand for lower-carbon products.

What types of policies help drive decarbonization?

Eliminating embodied carbon emissions is an ambitious goal: there is not just one type of policy required, but rather a full suite of policies targeting different users and strategies.  Read below for an overview of five types of embodied carbon policy, including (1) procurement policies, (2) building codes, (3) city planning and building ordinances, (4) climate action plans, and (5) waste management and circularity policies.

ec policy map

While embodied carbon procurement policy like ‘Buy Clean’ has only passed in the State of California and a number of cities, a growing number of states have introduced legislation in the past or for the 2021 legislative session and will be continuing to push for a bill.

#1 Procurement Policies (Buy Clean)

Public procurement policies shift government procurement towards lower-carbon materials, leveraging the purchasing power of governments to incentivize a similar shift in the broader construction materials market. There is a large range of actions offered by embodied carbon procurement policies, from including carbon as a criterion for awarding contracts, to requiring disclosure of embodied carbon data for materials used on public projects, to setting maximum carbon limits for key construction materials.

Spotlight: The first American iteration of this type of legislation, often referred to broadly as ‘Buy Clean’, was passed by the State of California in October 2017. The Buy Clean California Act [3500 – 3505] aims to limit state procurement of rebar, structural steel, mineral wool insulation, and flat glass to lower-carbon options beginning in January 2021.

Read More: To learn more about Buy Clean policies, including a policy and technical review, check out the Carbon Leadership Forum’s 2019 Buy Clean Washington Study.

#2 Building codes

Building codes are adopted by state and local jurisdictions to provide minimum requirements for the design and construction of buildings to protect the health and safety of building occupants. States and local jurisdictions can adopt amendments to the code to establish prescriptive or performance-based paths to reducing embodied carbon of specific construction materials or whole buildings.

Spotlight: In November 2019, Marin County adopted the Low Carbon Concrete Code, an amendment to the International Building Code that establishes limits on carbon emissions from concrete.  The code provides ten global warming potential thresholds by concrete strength by using limits for both cement content and embodied carbon. Projects can meet either cement or embodied carbon limits, at the scale of the concrete mix or the entire project.

#3 City Planning and Building Ordinances

Zoning, land use, and building regulations provide opportunities to incorporate embodied carbon requirements that target the private sector within a jurisdiction limit.  In addition to performance-based requirements requiring specific materials or whole buildings to meet embodied carbon targets or limits, zoning and land use policies have a large impact on embodied carbon by influencing density and building typology.  A range of incentives is also available through the zoning and building permitting process, such as awarding density bonuses or expedited permitting to low carbon projects.

Read more: To learn more about city-level embodied carbon policy strategies, check out the City Policy Framework For Dramatically Reducing Embodied Carbon.

#4 Climate Action Plans

Climate Action Plans (CAPs) establish a strategic framework and targets for measuring and reducing greenhouse gas emissions that are customized to the city or region they apply to. While these are not enforced legislation as described by the four policies above, they have a large influence on other types of policies. A detailed emissions inventory is the foundation of all CAPs, which allows the strategic planning body to set targets specific to the hot spots identified by the inventory. Depending on how comprehensive the CAP is, they may also include a prioritized action list tailored to regional constraints and opportunities and identify specific policy strategies and funding mechanisms.

Embodied carbon may be included in either the building section of a CAP or in the consumption or materials management section of a climate action plan.

Highlight: The City of Vancouver has a target to reduce the embodied emissions from new buildings by 40% by 2030, compared to a 2018 baseline. The Climate Emergency Action Plan report published in October 2020 includes recommendations for prescriptive material-specific requirements and performance-based whole building embodied carbon thresholds to be phased into city rezoning and new construction policy over the next ten years.

#5 Waste Management and Circularity Policy

Waste management and circularity policies support deconstruction and reuse of building materials during demolition or renovation and better recycling and construction waste management practices to reduce the demand for extracting new materials by extending the useful life of existing building materials.

In addition to policies that specifically target end-of-life management for materials, policies can require a ‘cradle-to-cradle’ rather than ‘cradle-to-gate’ approach to embodied carbon data across all types of policies to account for and promote sustainable end-of-life practices such as recycling, repair and reuse of materials.

Highlight: Portland became the first US city to pass a deconstruction ordinance in 2016, presenting the opportunity to save an estimated 4,000 annual tons of materials waste for reuse by expanding the definition of designated historic resources to ensure that valuable materials are salvaged for reuse instead of disposal.

Read more:  Stopwaste and ARUP, “Circular Economy in the Built Environment: Opportunities for Local Government Leadership,” 2018.

Embodied Carbon Policy Components: Disclosure, Incentives, and Limits

Different types of embodied carbon policies are typically composed of three main elements: (1) data and transparency (disclosure), (2) incentives, and (3) limits.  The first element, disclosure, is generally required, while the last two elements are optional but recommended. The appropriate combination of these three elements may depend on the region and level (i.e. local, state, or federal) at which they are being implemented.  Read below to learn more about these three elements and their expected outcomes.

This figure outlines some of the key steps and considerations for developing an embodied carbon policy, including scope, data, standards (limits), incentives, and compliance. While this article focuses on steps 2-4, stakeholder engagement and clear definition and communication regarding scope and compliance are key to the success of a bill.

Data and Transparency

Measurement and disclosure of supply chain carbon emissions are the foundation of all embodied carbon policies with performance-based pathways to compliance.  To limit or incentivize reductions of the emissions associated with a product, there must be an agreed-upon methodology for measuring and calculating the embodied carbon of products.

Data is typically disclosed in the form of an environmental product declaration (EPD). EPDs are independently-verified documents based on international standards that report the environmental impacts of a product. These declarations can be used to track supply-chain specific product data and compare products if the products are functionally equivalent and have a similar scope.

Policies requiring the disclosure of embodied carbon have the added value of increasing the availability of embodied carbon data for use by both the public and private sectors. Outcomes of policies with data and transparency components include:

  • Increased availability of environmental product declarations (EPDs)
  • Increased knowledge of disclosure standards and life cycle thinking
  • Increased quality and consistency of data resulting from harmonization of data collection standards
  • More robust, representative datasets to support future policies and research

Co-benefits for manufacturers who have created EPDs include a competitive advantage for projects meeting voluntary green building certification program requirements as well as general marketing and environmental reporting. The process of collecting data for the life cycle assessment may also identify opportunities for reduced energy consumption and other savings.


Policies can use incentives to encourage voluntary participation, support broader implementation, or reward high performance. The types of incentives available to policymakers vary widely depending on the jurisdiction. Examples of incentives include financial support (either through tax incentives or grants), technical support and training, density bonuses, approval fast-tracking, and preferential purchasing (i.e. bid incentives). Incentives may be provided indefinitely or only early during implementation of a new policy or through a voluntary trial period. Possible outcomes of policies with incentives include:

  • Integration of carbon into the bid selection process
  • Encouraging continued research and action by innovators and industry leaders through rewarding high performance
  • Increased participation for voluntary requirements or for voluntary trial periods
  • Providing targeted support for small businesses
  • Can support research or investment for technological upgrades related to manufacturing

Spotlight:  New York State Senate Bill S8965, also known as the NY State Low Embodied Carbon Concrete Leadership Act (LECCLA), was introduced in September 2020 and is currently in committee. LECCLA includes several types of incentives. First, it creates a preferential purchasing standard for low carbon concrete and for CO2 capture and utilization technologies. Second, it establishes a tax credit for concrete plants that create an EPD. The tax credit expires after the first two years of the program.

Product Emissions Limits

Policies can set performance-based product standards that use maximum embodied carbon limits to encourage innovation and allow for a technology-agnostic, market-based approach to industrial and building sector decarbonization. These limits may be lowered or reviewed at a regular interval to gradually lower in accordance with climate targets. Policies requiring embodied carbon limits may utilize a number of strategies to avoid concerns about data quality. Examples include a longer initial period of voluntary compliance, setting a conservative initial emissions limit, or including a data uncertainty range that allows products within a percentage range above and below the emission limit to comply.  Benefits of policies with emissions limits include:

  • Avoids emissions outsourcing and encourages domestic clean manufacturing solutions
  • Allows for development of new decarbonization strategies
  • Rewards companies that have invested in clean technologies to reduce their carbon footprint

This demonstrates how limits could decrease over time to align with targets set by the IPCC to stay below 1.5 degrees of warming. The initial cap could be set based on an industry ‘high’ baseline to accommodate for the variability in current data, and then decrease over time to still reach goals. This allows time for education and development of solutions for reaching net-zero.

Spotlight: A federal Buy Clean program was included in the discussion draft of the Climate Leadership and Environmental Action for our Nation’s (CLEAN) Future Act released by the House Committee on Energy & Commerce in January 2020. The draft act outlines a climate plan for the US to reach net-zero greenhouse gas pollution no later than 2050. The federal Buy Clean program includes all embodied carbon policy components described above: data, incentives, and limits.

Opportunities for Legislation and Action in 2021

In the United States, there are a number of places to look for Buy Clean legislation in 2021. At the state level, look out for procurement policies in New York State, Washington State, Oregon State, and possibly Minnesota and Colorado. All of these states either (1) have active bills or (2) have previously introduced Buy Clean legislation that did not pass and are reviewing new opportunities to introduce legislation. At the federal level, look for a federal Buy Clean program to be proposed as part of updated language related to the CLEAN Futures Act, federal infrastructure bills, and other Green New Deal legislation.

If you are looking for ways to get involved and voice your support of accelerated policy adoption, it may be helpful to connect with others who can direct you to relevant local policies.

  • Reach out to your local professional chapter (like the AIA) to identify local policies and opportunities for engagement
  • Find out when local policies like climate action plans and building codes will be re-evaluated or updated and identify the public comment period
  • Connect with the Carbon Leadership Forum Regional Hub in your area
  • Join the Policy Focus Group on the Carbon Leadership Forum Community Hub


by Meghan Lewis
CLF Research Scientist

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