Dec 23, 2022

2022 Embodied Carbon Policy—A Year in Review

In 2022, an unprecedented number of policies were introduced and passed addressing embodied carbon reductions in the building and infrastructure sector. We have continued to see interest in this topic increase at all levels of government as well as in the design community and corporate space.

by Megan Kalsman and Meghan Lewis
Carbon Leadership Forum research staff

Read on to hear a few highlights and make sure to stop by our Policy Toolkit where we publish resources and track updates in our embodied carbon policy map.

International Policy Action

Embodied carbon has gained attention on an international scale. In 2022, the United Nations Industrial Deep Decarbonisation Initiative announced a global coalition of governments committing to a Green Procurement Pledge to fight climate change by increasing demand for low-carbon industrial materials. Corporations have also committed to take action by creating markets for emerging clean technologies through the First Movers Coalition. The Coalition focuses on steel and aluminum (amongst other areas like shipping and trucking), with a new addition of the cement and concrete sector announced at COP 27 that took place in November 2022. Another announcement from COP 27 was that 158 ratifying countries to the Paris Agreement have included energy efficiency and building decarbonization in their national commitments.



Federal Policy Action

On the federal level, building off President Biden’s commitments in 2021 around clean manufacturing, we have seen significant actions supporting these efforts from the first days of 2022. In January, President Biden’s 2021 Executive Order on Federal Sustainability established the federal Buy Clean Taskforce. The Taskforce aims to increase federal purchasing of low-carbon construction materials while supporting American manufacturing companies. Federal agencies took action in the months following this announcement:

  • General Services Agency announced its Buy Clean program requiring low-carbon concrete and asphalt to be used in large public projects and requiring Environmental Product Declarations (EPDs).
  • Department of Transportation announced a pilot program to increase the use and transparency of EPDs and procure low-carbon materials for their infrastructure projects.
  • Federal Highway Administration awarded $7.1 million in grants to 35 projects across the US as part of their Climate Challenge to quantify emissions of sustainable pavements.

In August 2022, the passage of the Inflation Reduction Act allocated a total of $369 billion to finance climate change solutions from various levels. Specific to embodied carbon reductions, the law allocates $4.5 billion to the Environmental Protection Agency, Department of Transportation, and General Services Agency to procure climate-friendly construction materials for federally funded projects. Examples of funding relating to embodied carbon include:

  • Develop a low-embodied carbon labeling system for construction materials and increase EPD development and standardization.
  • Using and procuring low-carbon materials for federal buildings.
  • Research on emerging technologies related to building materials.
  • Funding transportation projects using lower embodied carbon materials.

Additionally, in September 2022, the White House announced the Federal Buy Clean Initiative stating that the federal government will prioritize purchasing lower greenhouse gas emission steel, concrete, asphalt, and flat glass. They will convene states to partner on Buy Clean policies, launch pilot programs to advance clean construction materials, and increase data transparency through supplier reporting. In October, the White House published a fact sheet that cited the CLF’s Regional Hubs, the CLF Embodied Carbon Educational Series, our published data and research, the SE2050 and MEP2040 commitments and companies, and highlighted many partners working in this space.

State and Regional Policy Action

In addition to the action on the federal level around embodied carbon, there has been progress on the state and regional levels as well. A few examples include:

  • Oregon’s Buy Clean bill was signed into law in March 2022 and will require the Oregon Department of Transportation to establish a framework for reducing greenhouse gas emissions related to the construction and maintenance of their projects.
  • California’s AB 2446 designates state agencies to develop a framework for measuring and then reducing the average carbon intensity of residential construction materials.
  • Washington State’s Buy Clean Buy Fair Pilot Study was completed in 2022 which developed a reporting database to collect environmental and labor information from state construction projects.
  • The Pacific Coast Collaborative Low Carbon Construction Taskforce announced at COP26 began convening in Spring 2022 to identify opportunities for regional alignment and action around embodied carbon.

Local Policy Action

Furthermore, we are seeing embodied carbon measures included in an increasing number of city and county climate action plans. See the CLF Policy Tracker for more info.

  • The City of Vancouver’s Whole Building Life Cycle Assessment zoning requirement became part of their Building By-Law which goes into effect in 2023.
  • New York City’s Executive Order 23 includes requirements for using low-carbon concrete on capital projects and concrete sidewalks, submitting EPDs to the EC3 tool, using low-emission vehicles and equipment, performing Life Cycle Analysis, and developing action plans that incorporate embodied carbon.
  • The City of Denver accepted two proposed amendments to its building code that address embodied carbon, specifically requiring EPDs and setting limits for concrete and steel.
  • San Francisco’s Construction and Demolition Law went into effect in January 2022. It sets debris recovery requirements for all projects in the City to be recycled or reused with no waste to landfill.




What’s Ahead?

2023 is set up to be yet another year of unprecedented action on embodied carbon policy. The US federal government, joined now by a growing set of international partners, will take bold action to reduce embodied in their building and infrastructure portfolio while providing funding, technical assistance, and other programs to states, cities, and companies across the country to implement reductions. Policies led by states, cities, and provinces will continue to lead the way and set precedent for legislative action by integrating embodied carbon across urban planning and building regulations as well as innovative incentive programs. Stay in touch with our policy team and reach out to tell us about new policies for the CLF Policy Tracker!

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