How the EPA is Driving Change Toward Cleaner Construction Materials

After years of advocating for product transparency, the EPA’s Label Program for Low Embodied Carbon Construction Materials has made it a reality, bringing with it the rise of Environmental Product Declarations (EPDs).

Human behavior is a finicky thing. To drive change, one must either offer the carrot or wield a big stick. The United States has opted for the carrot, leveraging its position as the world's largest purchaser, with annual spending of $630 billion, to incentivize the transition to cleaner construction materials through the “Buy Clean” initiative. 

This federal procurement program requires government contractors to use "clean" construction materials in the development of federal buildings and infrastructure projects. But the key question is: what qualifies as clean? In August 2024, this question, along with others, was addressed by the EPA’s Label Program for Low Embodied Carbon Construction Materials.

The new labeling program will define what qualifies as "clean." Initially, it will apply only to the most carbon-intensive construction materials—steel, glass, asphalt, and concrete—as this approach offers the most effective way to reduce a significant portion of the 15% of global greenhouse gas emissions attributed to construction materials.

The EPA has adopted a phased approach to implementing the labeling program, allowing all material categories to progress at an appropriate pace based on market maturity and available data. The program will follow these phases:

1. Phase I: Data Quality Improvement. Product category rules will be improved upon and standardized by the EPA to ensure that data collected from EPDs are consistent and verifiable.
2. Phase II: Threshold Setting. Use EPD data and other credible industry benchmarks to set thresholds that products must meet to qualify for a label under this program.
3. Phase III: Labeling Materials and Products. Begin assigning labels to materials and products that comply with the EPA’s program criteria.

The labeling program will operate under a tiered ranking system. Manufacturers that achieve the greatest reductions in their product's embodied carbon will be recognized for their innovation and ranked the highest. Thresholds for each tier will be determined by EPDs and industry benchmarks, with opportunities for public input and review.

Labeled products and materials will be listed in an EPA-maintained registry. The EPA tentatively plans to have initial products labeled by the end of September 2026.

The label program may expand to include materials beyond steel, glass, asphalt, and concrete, but it largely depends on the efforts of different material sectors to proactively meet the program’s requirements. Since participation is voluntary, manufacturers must be motivated to take the necessary steps to qualify.

Steps to Successfully Participate in the EPA Labeling Program

Manufacturers interested in joining the EPA’s new labeling program can start by developing EPDs for their products or by optimizing current manufacturing practices to lower embodied carbon, then acquiring EPDs for these more carbon-efficient iterations.

Below is a simple, straightforward overview of the steps manufacturers can take to participate in the new program.

1. Obtain EPDs for the products you manufacture. These EPDs will serve as a baseline measurement to assess the environmental impact of the product throughout its entire life cycle.
2. Use the EPD data to identify inefficiencies in the manufacturing process and create more carbon-efficient products.

As you can see, it's a simple two-step process: Obtain an EPD, check if it meets the threshold requirements to earn a label, and if not, optimize the manufacturing process to reduce the embodied carbon so that it qualifies.

The EPA will offer free technical assistance to manufacturers to help obtain EPDs for their products. While the start date for these services has not been announced, you can join their email list for updates.

Alternatively, you can take a proactive approach by utilizing Green Builder Media’s consulting services, where we guide you through the process of obtaining an EPD so you can be among the first manufacturers to have a product labeled under the new program.

Manufacturers can expect EPDs to become the new standard of doing business. Get an EPD now and enjoy the carrot before the stick forces your hand.